As the 9th of December draws near, approximately 47,000 UK firms are preparing to face the new Senior Managers & Certification Regime (SM&CR) introduced by the FCA. The new Regime aims to increase individual accountability and improve clarity of responsibilities within firms. This will improve how firms are governed but it also adds a new layer of administrative complexity, which could require a long and elaborate implementation process.
Many existing systems are costly and require a lengthy implementation period. However, EnOC has been designed to close the technology gap, where both the large and even the very small firms can have access to enterprise-level systems from a very low starting price point. EnOC’s SM&CR system, Accountability, can assist firms in addressing this new regime in an efficient and cost-effective manner. Intuitiveness and simplicity underpin EnOC; as a result, Accountability can be set up in just three simple steps.
Users will enter the details of their company and identifying them as enhanced, core or limited scope.
Users will then set up their department structure. Smaller companies consisting of only a handful of employees, who may not have designated departments, may skip this step altogether and progress directly to the third step.
All the users’ details are entered here, and individual responsibilities are assigned. After completing the three steps, EnOC will automatically generate (among others) the following:
From the members’ details page, EnOC will gather all the allocated responsibilities and automatically generate a responsibilities map. This map will list the relevant responsibility items as well as the name of the person responsible alongside it. This map is a mandatory requirement for Enhanced firms, but EnOC provides it as part of the basic package to all our SM&CR users, regardless of their classification.
EnOC will pivot the map and list the individuals. Alongside each individual, EnOC will show the responsibilities that have been assigned to them.
EnOC will retrieve all available relevant data from the system and pre-populate the SoR, leaving only the bespoke sections to be completed, substantially simplifying the process.
EnOC will retrieve all available relevant data from the system and pre-populate the Terms of References, leaving only the bespoke sections to be completed, substantially simplifying the process.
EnOC is designed as a paperless system. Where documents are created, e.g. Statement of Responsibilities, Terms of Reference, they are generated in electronic format and stored in the EnOC document management system. According to the SM&CR rules, these documents are required to be retained and EnOC makes retrieval and evidencing current and past versions a doddle.
Where required responsibilities are vacant, EnOC will issue advance warnings to alert the administrators, giving them notice to take appropriate action with regard to those vacant responsibilities.
This is the FCA’s new public register for checking the details of key individuals working in financial services. As soon as the programming specifications of The Directory are finalised, EnOC will support its clients by automating the submission process as much as is permissible.
Whilst excessive costs and complexity of systems may have been the reasons why companies normally decide against using external services, EnOC removes both those barriers to entry. EnOC’s mission is to close the technology gap and therefore its services are widely accessible at £25 per SMF, £12 per Certified individual and £3 for other individuals. Born in the cloud, EnOC is immensely scalable, able to serve both the very small to the very large businesses.
Whilst it may be possible to use spreadsheets to administer SM&CR, it would quickly descend into a tick-box exercise, and it would defeat the purpose of the initiative. EnOC significantly reduces the administration burden, removes complexities, and allows users to actually focus on the duties of responsibility and accountability.