The extension of the regime is excessive for most
smaller to medium-sized firms
The long-awaited Financial Conduct Authority (FCA) consultation
on extending the Senior Managers and Certification Regime (SMCR) to
most of the financial services industry has sent compliance
consultants into a frenzy.
In their efforts to capitalise on another regulatory change,
consultants are predicting more enforcement action against senior
individuals, difficulties in recruiting senior staff, fundamental
changes to organisational structures and governance processes, as
well as the inevitable burden of more policies and procedures.
Although some of these scenarios are plausible, there is an
alternative story that not much needs to change – or at least
not much needs to change for those who already take their
regulatory responsibilities seriously.