F&P360 for SMCR

Are you managing your SMCR compliance with dozens of spreadsheets?

We know that demonstrating compliance can be difficult and time-consuming as regulations impact various stages of the employment lifecycle. Get it wrong and your organisation could be at risk of:

  • Data breaches
  • Negative publicity
  • Financial penalties
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SMCR was first introduced in March 2016 for banking institutions to improve accountability and conduct and has since been extended to all FCA-regulated firms. 

Knowing the risks of non-compliance led us to create F&P360, an integrated solution that embeds SMCR data, reasonable steps and evidence in one place. No more relying on spreadsheets. No more wasted time on administrative tasks. F&P360 lets you focus on the business of your business.

SMCR Compliance

Here’s how F&P360 streamlines processes for SMCR compliance:

F&P assessments

The following are positive indicators of regular, thorough & consistent F&P assessments, according to the FCA.

  • F&P checks identify new issues with staff – some fail
  • Relevant SMFs actively oversee the F&P process and ensure appropriate reporting
  • Competence assessment demonstrates that thought has been given to each specific role (including managers)
  • Development plans are put in place as a result of F&P assessment
  • Managers are adequately trained in the firm’s approach to F&P and understand what is expected of them
  • A detailed F&P process has been introduced and integrated into existing HR/performance management processes (it covers what happens if someone fails F&P)
  • F&P panels – which include senior managers – are convened to consider marginal cases
  • Form has appropriate criteria and a robust process for identifying certification staff on an ongoing basis
  • Regulatory references disclose misconduct/relevant concerns and are produced in a timely manner

Compliance and culture

The FCA sees conduct training as a key element of positive culture and managing compliance.

  • SMF can demonstrate ownership and involvement/oversight of setting the tone (and requirements) of the training
  • Examples/scenarios draw out nuances of how the rules apply to each type of role
  • Line manager or supervisor engagement with training
  • Training is reinforced regularly and built into on-boarding
  • Effectiveness of Conduct Rules training is assessed
  • Training is put in the context of the overall regime
  • Regime/Conduct Rules are presented as a step change in regulatory expectations
  • Conduct is integrated into the F&P and performance assessment
  • Assess effectiveness of conduct training through employees maintaining accurate and up to date records, raising trigger events knowing an event has arisen, being able to raise an alert knowing HR will respond appropriately