Solvassure will help
to safeguard your
senior managers.

These regulations include the Senior Managers’ Regime, the Certification Regime and Conduct Rules, otherwise known as SM&CR or Accountability II.

UK banks, building societies, credit unions and investment firms are required to meet these rules, specifically any of the FCA and PRA regulated firms that went live with March 2016 or remaining regulated firms which must go live in 2018.

Unlimited fines and even custodial sentences for non-compliance have now been introduced and senior managers along with their compliance and HR teams are responsible for meeting and monitoring these complex regulations.

This has created a real operational challenge for individuals and businesses alike, because those at the top could now be exposed to considerable risk.

Anyone already covered under APER was grandfathered into Senior Management Functions and companies were required to provide a Statement of Responsibilities for each senior manager, along with a Management Responsibilities Map.

The FCA subsequently conducted its first supervisory review of these documents for all firms with an allocated supervisor and a sample of firms without.

This review was published on 28th September 2016 and considered to what extent the rules had been met.

Whilst it was apparent that many companies had invested considerable time and effort to comply, not everyone had succeeded.

In some cases, it wasn’t clear whether firms had identified sufficiently senior individuals to hold Senior Management Functions.

In others, not all business functions had been allocated as responsibilities or there wasn’t enough detail about their scope.

There was wide variation in the quality of responsibilities maps, some with unclear or missing information.

This included governance arrangements and was particularly noticeable where the firm was part of a larger group.

It did not interrogate the dynamic elements of each business that have moved on since the firms went live in March 2016.

Statements of Responsibilities and Management Responsibilities Maps must be accurate for any date in the past, but when departments are modified, created or dissolved, the structure of an organisation changes.

Historical variations in reporting lines across geographical and departmental boundaries also need to be traced.

Permanent leavers, new starters and temporary suspensions must be reported with Handover Certificates.

Relinquished, new and modified roles and responsibilities must be accounted for and the acquisition or disposition of a business would require compliance frameworks to be merged.

Add to this the introduction of the Certification Regime, Conduct Rules and Duty of Responsibility and it’s easy to see why accountable executives are feeling nervous.

Many have chosen to rely on manual solutions created by management consultants or temporary staff and underpinned by spreadsheets, ink signatures and document repositories.

Whether through meetings, emails, phone calls, spreadsheets or data extraction, gathering accurate compliance information can be a time consuming, frustrating and costly process.

• In most firms data is distributed across an array of systems, making it difficult to get hold of.
• Anything kept on a spreadsheet is at risk of being overwritten with limited scope for real time analysis or historical audit.
• Status and priority measurements can be inconsistent making genuine problems hard to identify.
• Unnecessary time can be spent writing emails, organising meetings and sending text messages.
• Careless typing could direct emailed reports to an unintended audience and inadequate security measures could even put them into the wrong hands.
• When the data is finally presented it is often obsolete due to the monthly reporting cycle.
• Significant costs can be incurred running a team of well paid individuals to collate, analyse and document reporting data before they leave, taking critical knowledge with them.

The regulator is likely to come down hard on any person who wilfully contravenes the rules or does not make an effort to build a sustainable compliance framework.

Senior managers should bear this in mind because compliance is binary and it only takes one mistake to fail.

• Resource accountability can be improved and perhaps more critically, historical reports generated at the touch of a button.
• It could also help to lower the risk of penalties for breaches along with the associated operating costs.
• Organisations that have already invested in a digital solution need to make sure that their vendor is licensed by the FCA and the PRA to use copyright Handbook material.
• They should also avoid getting locked into a single-regulation option which would mean further investment for future compliance needs.
• For anyone confident that their manual solution is cost effective and fit for purpose, there is always the next regulator review to look forward to.

In addition to capturing responsibilities and producing regulatory documentation, it tackles the complex challenge of demonstrating “reasonable steps”, which we consider to be the fourth element of the regime. (Draw this graphic with its bullet point lists)

This is achieved by sending out pre-defined assurance checks to activity owners, evidencing attestations with supporting material and highlighting exceptions to key stakeholders in real time.

Fully automated checks include low level regulations, committee governance, executive on-boarding, department KPI’s and best practise workflow providing real time exceptions and detailed evidence to protect senior managers.

It also handles key compliance processes by importing published regulations, running impact analyses, compiling business requirements and implementing monitoring indicators which enable end-to-end traceability.

Solvassure eliminates the need for update meetings, phone calls, emails and spreadsheets by providing secure compliance data with status and priority settings online twenty-four seven.

Cloud based and mobile technology uses copyright material licensed to us by the FCA and the PRA with a continually expanding regulatory library that goes well beyond the regime.

This means that other compliance initiatives for regulations such as MiFID II and GDPR can be consolidated using our technology, with assurance material tailored specifically for each firm.

Our technology reduces the time it takes:

• Legal counsel to access regulatory publications and run legal entity impact analyses.
• Change directors to compile business requirements and implement regulatory monitoring indicators.
• Compliance directors to produce current and historical Statements of Responsibilities, Management Responsibilities Maps and annual FIT certificates.
• Senior managers to access evidence relating to their duty of responsibility obligations, with all relevant compliance data in one place.
• Chief executive officers, non-executive directors and auditors to satisfy themselves that governance obligations are being met across a group of companies.
• Compliance directors to implement common compliance standards across different sets of rules.
• HR departments to on-board and train a senior manager and provide him or her with a checklist of activities relating to direct reports and third party suppliers.
• HR directors to compile meaningful benchmark data, identify poor performers and reward good performers.
• The regulator to access detailed historical evidence in the event of an investigation.

Our technology saves you money on:

• Legal counsel by enabling faster access to regulatory publications and associated documentation.
• Technology frameworks by consolidating compliance activities into one system and reducing hardware, infrastructure, software and support overheads.
• Meetings, phone calls, emails and corporate travel by automating the process of information gathering.
• Training activities by delivering function specific assurance checks and targeted online learning courses to relevant personnel.
• External consultants by creating a centre of excellence for senior managers, compliance personnel and human resource representatives, making them self sufficient.
• Tracking different regulations by implementing common compliance standards and best practice in a single digital framework.
• Regulatory penalties by remaining compliant and maintaining easy access to detailed historical evidence in the event of an investigation.

Our technology enables:

• Compliance and human resource departments to cover more ground with the same resources.
• New business opportunities to be created by lowering corporate governance risk and improving customer confidence.
• Investor relations to be improved by using new compliance metrics to meet published regulatory targets.
• New products to be brought to market sooner with an effective regulatory framework that can process compliance requirements more effectively.
• More employee collaboration by using a single trusted platform that not only delivers accurate instructions but also provides stakeholder communication.

• Base User License – System access for all users including maintenance and upgrades.
• Smart Phone License – Access for all base users, including GPS location marking, maintenance and upgrades.
• Professional Services – Project manager, implementation consultant, application developer, system tester.
• Help Desk – In house client team trained for first line support and Solvassure analysts for second line support.
• Environment Hosting – Secure cloud based in the United Kingdom.
• Data Storage – Evidence and template documents can be stored in our hosted environment.
• Partner Services – Translation any foreign language using our chosen language partner.
• Content Licensing – Licensed content from the FCA, the PRA and the UK government.

Find out more about how our cost effective technology could help a senior manager in your firm avoid the punitive measures that accompany the regime.