From experience, the following are key to delivering a successful SMCR implementation project:
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Setting the tone at the top to embed the right culture adopting the spirit, not just the letter of the regulations
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Strong project sponsorship and leadership; competent and capable project teams: combining subject matter and project management knowledge and experience
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Early engagement of all those who are impacted. Tailored communications are critical
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The project scale should not be underestimated, it should be adequately resourced and funded
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The burden of implementation will vary depending on the firm’s size and complexity, and regulators expect firms to take a proportionate approach. However the actual activities remain largely the same regardless of the size of the firm
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Allocating responsibilities under SMCR has very serious implications and shouldn’t be seen as a compliance box‑ticking exercise. Can lead to structural and org chart changes
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Ownership of SMCR BAU process post implementation should be agreed at the earliest stage
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SMCR requirements need to be embedded into business-as-usual and integrated into processes (notably in the HR space); technology needs to support that
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Training for all affected staff needs to be meaningful (e.g. Conduct Rules)
If you have any questions or require any support we have a range of specialist services to help you interpret how the regulation applies to your firm and develop a pragmatic approach to implementation and ongoing compliance.
