The new SMR seeks to strengthen personal accountability in financial institutions.
This article was written by Mark Holmes, CEO of Waymark Tech.
The FCA’s Senior Managers Regime (SMR) puts accountability front and center. Originally introduced in 2016 for larger banks and insurers, it’s set to be extended to almost all UK firms next year. However, its impact will be felt in the US and elsewhere too.
It also requires these senior individuals to be certificated on an annual basis, and make sure all their staff act with integrity, care, skill, and diligence; remain open and cooperative with regulators; pay due regard to the interests of customers; and observe the proper standards of market conduct
It’s got a long reach too, and is likely to impact almost all global financial institutions. That’s because it applies to UK-based subsidiaries of non-UK firms and will also extend, in slightly modified form, to UK branches of non-UK banks. So SMR will have a significant impact on everyone in the financial services industry.
But many smaller firms just aren’t ready – and this isn’t such a surprise. According to KPMG, when bankers first saw the regulations nearly half of them said it would have a greater impact than they’d expected. That’s because SMR is not merely about filing another form with the regulator, as some people think. It goes much further; it will often require firms to put in place organizational reforms to make sure that accountability is clear and transparent.
In addition, the FCA is getting tough on management accountability. According to Wolters and Kluwer, 39 per cent of recorded penalties since 2013 have been due to "management and control" failures.
Mary Steven, the global regulatory analysis manager at Wolters Kluwer, agrees: "The SMR is set to be extended to all authorised firms in 2018 and from this point we are likely to see an even greater increase in the number of cases reaching final notice stage."
The difficulty is turning the regulations into action
But what's the problem? The real difficulty for smaller firms is taking the regulations and turning them into practical action. For example, what does it mean in practice for officers to "pay due regard to the interests of customers"? Does it mean every decision needs an evaluation exercise to assess how it will interface with customer interests? Do you have to keep this on file to evidence a document trail if the regulator comes knocking?
In fairness, the FCA has done its best, publishing case studies showing how the rules could be applied in practice. But the financial services industry is huge and diverse – some firms have thousands of employees, some perhaps just five. There can’t ever be enough case studies to cover every firm and every situation.
We know interpreting SMR is going to be a challenge for small firms because the big organisations struggled too. Julian Bentley, Head of Risk and Compliance at Alderbrooke, wrote last year that "even now – six months later – some firms continue to struggle due to a lack of clarity and understanding," and there were "many gray areas for businesses".
Sharing knowledge is the solution
But there is a way forward, I believe. Eighteen months after the rules were originally applied to bigger financial institutions, we haven't yet seen the FCA call anyone out for making mistakes in implementation. The big banks seem to have done well, as least so far. They understand SMR and have worked hard to comply. This begs the question: what can everyone else learn from them – and how?
Frankly, we’re at a crossroads. Either smaller firms invest as much money again to find the solutions that the biggest banks have already found; or the banks share their know-how, best practice, and lessons from the process and help minimize the costs for new smaller organizations. I'm firmly of the view that the latter is the better, and it could provide a test-bed for collaboration across the financial services sector.
The obvious objection is that it would be nonsense for a big bank to give away this knowledge freely to help a competitor. But I think that's wrong. The next decade will see a huge avalanche of regulations packages, and to have a chance of coping, the industry as a whole must radically change the way it deals with and implements these regulations.
To be successful, we need to smash down the Chinese walls between compliance departments on Wall Street and within the City; open up to each other and start sharing our knowledge. It will save us all money in the long run, and this is where technology fits in. We can now allow people to connect in real time and share knowledge over the Internet. But at the moment, in financial services, we aren't taking full advantage of this at all. Instead we’re choosing to keep ourselves holed up, or else discuss things in 1-2 day windows at conferences.
And there are two other vital outcomes here: lower costs and higher public approval. If the industry works together, compliance costs will inevitably fall. This means costs for consumers could fall too – or at least not rise due to compliance. If we’re seen to be taking steps to directly address efficiency and therefore costs, people’s opinion of the financial services industry will undoubtedly rise.
Regtech can help. This is where smaller financial services firms can also fit in – and help bigger banks. The fact that smaller banks are more agile and open to using new technology than larger organisations means that they can become the proving ground for this new technology. Once the tech has been verified, the larger banks can then follow suit and adopt it too.
Smaller firms will need to make sure they’re ready for SMR by 2018. They have a lot learn from the biggest banks. It makes sense for everyone to share best practice. It is a genuine win-win.
This article was written by Mark Holmes, CEO of Waymark Tech.
The FCA’s Senior Managers Regime (SMR) puts accountability front and center. Originally introduced in 2016 for larger banks and insurers, it’s set to be extended to almost all UK firms next year. However, its impact will be felt in the US and elsewhere too.
It also requires these senior individuals to be certificated on an annual basis, and make sure all their staff act with integrity, care, skill, and diligence; remain open and cooperative with regulators; pay due regard to the interests of customers; and observe the proper standards of market conduct
It’s got a long reach too, and is likely to impact almost all global financial institutions. That’s because it applies to UK-based subsidiaries of non-UK firms and will also extend, in slightly modified form, to UK branches of non-UK banks. So SMR will have a significant impact on everyone in the financial services industry.
But many smaller firms just aren’t ready – and this isn’t such a surprise. According to KPMG, when bankers first saw the regulations nearly half of them said it would have a greater impact than they’d expected. That’s because SMR is not merely about filing another form with the regulator, as some people think. It goes much further; it will often require firms to put in place organizational reforms to make sure that accountability is clear and transparent.
In addition, the FCA is getting tough on management accountability. According to Wolters and Kluwer, 39 per cent of recorded penalties since 2013 have been due to "management and control" failures.
Mary Steven, the global regulatory analysis manager at Wolters Kluwer, agrees: "The SMR is set to be extended to all authorised firms in 2018 and from this point we are likely to see an even greater increase in the number of cases reaching final notice stage."
The difficulty is turning the regulations into action
But what's the problem? The real difficulty for smaller firms is taking the regulations and turning them into practical action. For example, what does it mean in practice for officers to "pay due regard to the interests of customers"? Does it mean every decision needs an evaluation exercise to assess how it will interface with customer interests? Do you have to keep this on file to evidence a document trail if the regulator comes knocking?
In fairness, the FCA has done its best, publishing case studies showing how the rules could be applied in practice. But the financial services industry is huge and diverse – some firms have thousands of employees, some perhaps just five. There can’t ever be enough case studies to cover every firm and every situation.
We know interpreting SMR is going to be a challenge for small firms because the big organisations struggled too. Julian Bentley, Head of Risk and Compliance at Alderbrooke, wrote last year that "even now – six months later – some firms continue to struggle due to a lack of clarity and understanding," and there were "many gray areas for businesses".
Sharing knowledge is the solution
But there is a way forward, I believe. Eighteen months after the rules were originally applied to bigger financial institutions, we haven't yet seen the FCA call anyone out for making mistakes in implementation. The big banks seem to have done well, as least so far. They understand SMR and have worked hard to comply. This begs the question: what can everyone else learn from them – and how?
Frankly, we’re at a crossroads. Either smaller firms invest as much money again to find the solutions that the biggest banks have already found; or the banks share their know-how, best practice, and lessons from the process and help minimize the costs for new smaller organizations. I'm firmly of the view that the latter is the better, and it could provide a test-bed for collaboration across the financial services sector.
The obvious objection is that it would be nonsense for a big bank to give away this knowledge freely to help a competitor. But I think that's wrong. The next decade will see a huge avalanche of regulations packages, and to have a chance of coping, the industry as a whole must radically change the way it deals with and implements these regulations.
To be successful, we need to smash down the Chinese walls between compliance departments on Wall Street and within the City; open up to each other and start sharing our knowledge. It will save us all money in the long run, and this is where technology fits in. We can now allow people to connect in real time and share knowledge over the Internet. But at the moment, in financial services, we aren't taking full advantage of this at all. Instead we’re choosing to keep ourselves holed up, or else discuss things in 1-2 day windows at conferences.
And there are two other vital outcomes here: lower costs and higher public approval. If the industry works together, compliance costs will inevitably fall. This means costs for consumers could fall too – or at least not rise due to compliance. If we’re seen to be taking steps to directly address efficiency and therefore costs, people’s opinion of the financial services industry will undoubtedly rise.
Regtech can help. This is where smaller financial services firms can also fit in – and help bigger banks. The fact that smaller banks are more agile and open to using new technology than larger organisations means that they can become the proving ground for this new technology. Once the tech has been verified, the larger banks can then follow suit and adopt it too.
Smaller firms will need to make sure they’re ready for SMR by 2018. They have a lot learn from the biggest banks. It makes sense for everyone to share best practice. It is a genuine win-win.
Get ready to mark your calendars for FMAS:24, returning this May! Take a quick glimpse of what awaits at the Sandton Convention Centre in Sandton, South Africa from May 20-22, 2024.
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Don't miss out on this 5-second invite packed with energy and urgency!
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Join 3500+ Attendees at FMAS:24 | Africa's Premium Financial Event
Join 3500+ Attendees at FMAS:24 | Africa's Premium Financial Event
Join 3500+ Attendees at FMAS:24 | Africa's Premium Financial Event
Join 3500+ Attendees at FMAS:24 | Africa's Premium Financial Event
Join 3500+ Attendees at FMAS:24 | Africa's Premium Financial Event
Join 3500+ Attendees at FMAS:24 | Africa's Premium Financial Event
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Looking to expand your network in #Africa? Join 3500+ attendees at FMAS:24, where online trading, fintech, payments, and crypto meet! Connect with industry leaders and innovators for an unmatched networking experience.
20-22 MAY 2024
Sandton Convention Center, Sandton, South Africa
Register now to secure your spot: https://bit.ly/3JbUpCK
#fmas #fmas24 #fmevents #networking #finance #africa
📣 Stay updated with the latest in finance and trading!
Follow Finance Magnates for news, insights, and event updates across our social media platforms. Connect with us today:
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Join 3500+ Attendees at FMAS:24 - Africa's Premium Financial Event
Join 3500+ Attendees at FMAS:24 - Africa's Premium Financial Event
Join 3500+ Attendees at FMAS:24 - Africa's Premium Financial Event
Join 3500+ Attendees at FMAS:24 - Africa's Premium Financial Event
Join 3500+ Attendees at FMAS:24 - Africa's Premium Financial Event
Join 3500+ Attendees at FMAS:24 - Africa's Premium Financial Event
Looking to expand your network in #Africa?
Join 3500+ attendees at FMAS:24, where online trading, fintech, payments, and crypto meet! Connect with industry leaders and innovators for an unmatched networking experience.
20-22 MAY 2024
Sandton Convention Center, Sandton, South Africa
Register now to secure your spot: https://bit.ly/3JbUpCK
#fmas #fmas24 #fmevents #networking #finance #africa
Looking to expand your network in #Africa?
Join 3500+ attendees at FMAS:24, where online trading, fintech, payments, and crypto meet! Connect with industry leaders and innovators for an unmatched networking experience.
20-22 MAY 2024
Sandton Convention Center, Sandton, South Africa
Register now to secure your spot: https://bit.ly/3JbUpCK
#fmas #fmas24 #fmevents #networking #finance #africa
Looking to expand your network in #Africa?
Join 3500+ attendees at FMAS:24, where online trading, fintech, payments, and crypto meet! Connect with industry leaders and innovators for an unmatched networking experience.
20-22 MAY 2024
Sandton Convention Center, Sandton, South Africa
Register now to secure your spot: https://bit.ly/3JbUpCK
#fmas #fmas24 #fmevents #networking #finance #africa
Looking to expand your network in #Africa?
Join 3500+ attendees at FMAS:24, where online trading, fintech, payments, and crypto meet! Connect with industry leaders and innovators for an unmatched networking experience.
20-22 MAY 2024
Sandton Convention Center, Sandton, South Africa
Register now to secure your spot: https://bit.ly/3JbUpCK
#fmas #fmas24 #fmevents #networking #finance #africa
Looking to expand your network in #Africa?
Join 3500+ attendees at FMAS:24, where online trading, fintech, payments, and crypto meet! Connect with industry leaders and innovators for an unmatched networking experience.
20-22 MAY 2024
Sandton Convention Center, Sandton, South Africa
Register now to secure your spot: https://bit.ly/3JbUpCK
#fmas #fmas24 #fmevents #networking #finance #africa
Looking to expand your network in #Africa?
Join 3500+ attendees at FMAS:24, where online trading, fintech, payments, and crypto meet! Connect with industry leaders and innovators for an unmatched networking experience.
20-22 MAY 2024
Sandton Convention Center, Sandton, South Africa
Register now to secure your spot: https://bit.ly/3JbUpCK
#fmas #fmas24 #fmevents #networking #finance #africa
Where the Prop Trading Industry Goes from Here | Finance Magnates Podcast
Where the Prop Trading Industry Goes from Here | Finance Magnates Podcast
Where the Prop Trading Industry Goes from Here | Finance Magnates Podcast
Where the Prop Trading Industry Goes from Here | Finance Magnates Podcast
Where the Prop Trading Industry Goes from Here | Finance Magnates Podcast
Where the Prop Trading Industry Goes from Here | Finance Magnates Podcast
Explore the tumultuous world of prop trading in this Finance Magnates podcast episode, featuring insights from Head of Axi Select, Greg Rubin.
We're discussing the challenges and shifts caused by MetaQuotes' pivotal decisions affecting MT4 and MT5 users, and how Axi Select offers a unique, realistic path to professional trading, steering clear of traditional prop firm pitfalls.
Tune in for expert analysis on the future of trading and innovative funding models.
The Axi Select programme is only available to clients of AxiTrader Limited. CFDs carry a high risk of investment loss. In our dealings with you, we will act as a principal counterparty to all of your positions. This content is not available for AU, NZ, EU and UK residents. For more information, refer to our Terms of Service. Standard trading fees apply.
This content is provided solely for general informational purposes and should not be construed as financial product advice or an investment recommendation. It has been prepared without considering your personal circumstances.
📣 Stay updated with the latest in finance and trading!
Follow Finance Magnates for news, insights, and event updates across our social media platforms. Connect with us today:
🔗 LinkedIn: https://www.linkedin.com/company/financemagnates/
👍 Facebook: https://www.facebook.com/financemagnates/
📸 Instagram: https://www.instagram.com/financemagnates_official
🐦 X (Twitter): https://twitter.com/financemagnates/
📡 RSS Feed: https://www.financemagnates.com/feed/
▶️ Telegram: https://t.me/financemagnatesnews
Don't miss out on our latest videos, interviews, and event coverage.
🔔 Subscribe to our YouTube channel for more!🔔
Explore the tumultuous world of prop trading in this Finance Magnates podcast episode, featuring insights from Head of Axi Select, Greg Rubin.
We're discussing the challenges and shifts caused by MetaQuotes' pivotal decisions affecting MT4 and MT5 users, and how Axi Select offers a unique, realistic path to professional trading, steering clear of traditional prop firm pitfalls.
Tune in for expert analysis on the future of trading and innovative funding models.
The Axi Select programme is only available to clients of AxiTrader Limited. CFDs carry a high risk of investment loss. In our dealings with you, we will act as a principal counterparty to all of your positions. This content is not available for AU, NZ, EU and UK residents. For more information, refer to our Terms of Service. Standard trading fees apply.
This content is provided solely for general informational purposes and should not be construed as financial product advice or an investment recommendation. It has been prepared without considering your personal circumstances.
📣 Stay updated with the latest in finance and trading!
Follow Finance Magnates for news, insights, and event updates across our social media platforms. Connect with us today:
🔗 LinkedIn: https://www.linkedin.com/company/financemagnates/
👍 Facebook: https://www.facebook.com/financemagnates/
📸 Instagram: https://www.instagram.com/financemagnates_official
🐦 X (Twitter): https://twitter.com/financemagnates/
📡 RSS Feed: https://www.financemagnates.com/feed/
▶️ Telegram: https://t.me/financemagnatesnews
Don't miss out on our latest videos, interviews, and event coverage.
🔔 Subscribe to our YouTube channel for more!🔔
Explore the tumultuous world of prop trading in this Finance Magnates podcast episode, featuring insights from Head of Axi Select, Greg Rubin.
We're discussing the challenges and shifts caused by MetaQuotes' pivotal decisions affecting MT4 and MT5 users, and how Axi Select offers a unique, realistic path to professional trading, steering clear of traditional prop firm pitfalls.
Tune in for expert analysis on the future of trading and innovative funding models.
The Axi Select programme is only available to clients of AxiTrader Limited. CFDs carry a high risk of investment loss. In our dealings with you, we will act as a principal counterparty to all of your positions. This content is not available for AU, NZ, EU and UK residents. For more information, refer to our Terms of Service. Standard trading fees apply.
This content is provided solely for general informational purposes and should not be construed as financial product advice or an investment recommendation. It has been prepared without considering your personal circumstances.
📣 Stay updated with the latest in finance and trading!
Follow Finance Magnates for news, insights, and event updates across our social media platforms. Connect with us today:
🔗 LinkedIn: https://www.linkedin.com/company/financemagnates/
👍 Facebook: https://www.facebook.com/financemagnates/
📸 Instagram: https://www.instagram.com/financemagnates_official
🐦 X (Twitter): https://twitter.com/financemagnates/
📡 RSS Feed: https://www.financemagnates.com/feed/
▶️ Telegram: https://t.me/financemagnatesnews
Don't miss out on our latest videos, interviews, and event coverage.
🔔 Subscribe to our YouTube channel for more!🔔
Explore the tumultuous world of prop trading in this Finance Magnates podcast episode, featuring insights from Head of Axi Select, Greg Rubin.
We're discussing the challenges and shifts caused by MetaQuotes' pivotal decisions affecting MT4 and MT5 users, and how Axi Select offers a unique, realistic path to professional trading, steering clear of traditional prop firm pitfalls.
Tune in for expert analysis on the future of trading and innovative funding models.
The Axi Select programme is only available to clients of AxiTrader Limited. CFDs carry a high risk of investment loss. In our dealings with you, we will act as a principal counterparty to all of your positions. This content is not available for AU, NZ, EU and UK residents. For more information, refer to our Terms of Service. Standard trading fees apply.
This content is provided solely for general informational purposes and should not be construed as financial product advice or an investment recommendation. It has been prepared without considering your personal circumstances.
📣 Stay updated with the latest in finance and trading!
Follow Finance Magnates for news, insights, and event updates across our social media platforms. Connect with us today:
🔗 LinkedIn: https://www.linkedin.com/company/financemagnates/
👍 Facebook: https://www.facebook.com/financemagnates/
📸 Instagram: https://www.instagram.com/financemagnates_official
🐦 X (Twitter): https://twitter.com/financemagnates/
📡 RSS Feed: https://www.financemagnates.com/feed/
▶️ Telegram: https://t.me/financemagnatesnews
Don't miss out on our latest videos, interviews, and event coverage.
🔔 Subscribe to our YouTube channel for more!🔔
Explore the tumultuous world of prop trading in this Finance Magnates podcast episode, featuring insights from Head of Axi Select, Greg Rubin.
We're discussing the challenges and shifts caused by MetaQuotes' pivotal decisions affecting MT4 and MT5 users, and how Axi Select offers a unique, realistic path to professional trading, steering clear of traditional prop firm pitfalls.
Tune in for expert analysis on the future of trading and innovative funding models.
The Axi Select programme is only available to clients of AxiTrader Limited. CFDs carry a high risk of investment loss. In our dealings with you, we will act as a principal counterparty to all of your positions. This content is not available for AU, NZ, EU and UK residents. For more information, refer to our Terms of Service. Standard trading fees apply.
This content is provided solely for general informational purposes and should not be construed as financial product advice or an investment recommendation. It has been prepared without considering your personal circumstances.
📣 Stay updated with the latest in finance and trading!
Follow Finance Magnates for news, insights, and event updates across our social media platforms. Connect with us today:
🔗 LinkedIn: https://www.linkedin.com/company/financemagnates/
👍 Facebook: https://www.facebook.com/financemagnates/
📸 Instagram: https://www.instagram.com/financemagnates_official
🐦 X (Twitter): https://twitter.com/financemagnates/
📡 RSS Feed: https://www.financemagnates.com/feed/
▶️ Telegram: https://t.me/financemagnatesnews
Don't miss out on our latest videos, interviews, and event coverage.
🔔 Subscribe to our YouTube channel for more!🔔
Explore the tumultuous world of prop trading in this Finance Magnates podcast episode, featuring insights from Head of Axi Select, Greg Rubin.
We're discussing the challenges and shifts caused by MetaQuotes' pivotal decisions affecting MT4 and MT5 users, and how Axi Select offers a unique, realistic path to professional trading, steering clear of traditional prop firm pitfalls.
Tune in for expert analysis on the future of trading and innovative funding models.
The Axi Select programme is only available to clients of AxiTrader Limited. CFDs carry a high risk of investment loss. In our dealings with you, we will act as a principal counterparty to all of your positions. This content is not available for AU, NZ, EU and UK residents. For more information, refer to our Terms of Service. Standard trading fees apply.
This content is provided solely for general informational purposes and should not be construed as financial product advice or an investment recommendation. It has been prepared without considering your personal circumstances.
📣 Stay updated with the latest in finance and trading!
Follow Finance Magnates for news, insights, and event updates across our social media platforms. Connect with us today:
🔗 LinkedIn: https://www.linkedin.com/company/financemagnates/
👍 Facebook: https://www.facebook.com/financemagnates/
📸 Instagram: https://www.instagram.com/financemagnates_official
🐦 X (Twitter): https://twitter.com/financemagnates/
📡 RSS Feed: https://www.financemagnates.com/feed/
▶️ Telegram: https://t.me/financemagnatesnews
Don't miss out on our latest videos, interviews, and event coverage.
🔔 Subscribe to our YouTube channel for more!🔔