Read the editorial featured in the FT Adviser SM&CR special report.
How it all started
In 2018, we began exploring different ways to address the Senior Managers & Certification Regime (SM&CR). We considered running the project manually using spreadsheets, buying vendor systems or building our own software. We eliminated the manual spreadsheet option as it would have descended into a tick-box exercise, thus defeating the purpose of the SM&CR initiative.
At the same time, we also looked at vendor systems and saw that some were robust and certainly capable but most required computer hardware, space in the server room, manpower for maintenance, expensive software updates, high annual charges and one to three months implementation.
In a nutshell, this road was shaping up to be long, complicated and expensive. We did not have the time nor resources to get it wrong. This is how we came to decide to build our own solution; ensuring its design from a practitioner’s point of view, engineering out complexities, building it in the cloud, scalable, swift to deploy and accessible. This was how EnOC was born.
Building a solution
Our concern going into preparations for SM&CR was how to automate the prescriptive and time-consuming administrative requirements, while our staff and our management focused on the duties of responsibility and accountability, and not on mountains of SM&CR paperwork. We also recognised the pressures of manually monitoring thousands of data points, and maintaining the data for each applicable individual within the company.
It was apparent that a technical solution was needed. We already knew that vendor systems were expensive, so, why not build it ourselves? We have 20 years of experience building our own web-based systems. Our customer relationship management, management information, human resources, trading, compliance, investment suitability, client portal, document warehouse and many other tools were all built in-house, integrated seamlessly within one central Platform. We could certainly do it again.
From the start, we knew it was crucial to have one central database, a clear data structure, and a consistent user interface throughout the platform. We also needed a secure way to store the information, whilst keeping it conveniently retrievable for audit purposes. With defined objectives in mind, we pooled our combined experience together for our SM&CR project and planned the system design specification. We designed the platform to be paperless from the outset. The result was the EnOC Pro Platform; a cloud-based system that is scalable, cost-effective, intuitive and fit for purpose.
Uncomplicating SM&CR for our staff
We had made a start, we had a concept for a platform. However, we still needed to engineer out complexities, automating the processes and routines, and making SM&CR administration simple for our staff and management. In order for our team to focus on fulfilling the intentions of the Regime, it was imperative that we minimise the learning curve and shorten the implementation period. To do so, we designed the platform with a simple three-step process: enter the firm’s details, enter the departments and enter the individuals within the firm.
The next task was to make the tool intuitive; able to produce the required administrative output ‘at the click of a button’. Thanks to the simple setup process, we very swiftly had our core data and every individual in the company added to the platform. Next, we used the core data to automatically pre-populate the responsibilities map, the statement of responsibilities, the governance and committee’s terms of references, amongst others. Once completed, we had our first expansion to the platform: Accountability.
Accountability for SM&CR
Accountability can accommodate companies from a handful of staff, to companies with thousands. Accountability automatically generates the following from core data:
Responsibilities Map - all relevant responsibilities must be allocated to a minimum of one person; meaning no responsibility must be left unaccounted for.
Responsibilities Map (by individuals) – Accountability also pivots the Responsibilities Map listing individuals and then their functions, a useful indicator to identify individuals with too many responsibilities.
Statement of Responsibilities (SoR) – Accountability pre-populates much of the SoR, leaving only the bespoke sections to be completed.
Governance & Committees (incl. Terms of References) – similar to the SoR, Accountability pre-populates much of the Terms of References, leaving only the bespoke sections to be completed.
Documentation & Evidencing – the Platform generates electronic copies of all SoRs, Terms of References and other required documents, and stores them safely within the platform.
Fit & Proper Declaration – each user can complete their yearly Fit & Proper Declaration via the Platform, which notifies them to renew before the year is up.
Warnings and Alerts – the Pro Platform will issue advance warnings to alert administrators; prompting them to allocate any vacant responsibilities to the appropriate individuals.
Deadline Reminders – the system issues deadline reminders where annual reviews may be required, such as the SoRs and the Terms of References.
FCA’s The Directory – the Platform is designed to output data in the format that is required by the FCA; simplifying and assisting companies with their SM&CR submissions.
Transparency – administrators can decide the level of access to be given to users, providing administrators with control over the platform.
Closing the technology gap with EnOC
We have been able to build our systems in-house, for which we are grateful, designed by practitioners for practitioners; but unfortunately not all businesses have the resources nor the capability to do the same. High costs, long implementation periods and managing SM&CR with spreadsheets is less than ideal. The 9th December deadline is fast-approaching, and there may be firms who are not yet ready.
Firms need a system that can help them catch up in the shortest possible time. We have gone through it, so we know how difficult it can be. The EnOC Pro Platform helped speed up our journey. It is designed to relieve the disproportionate pressures placed on small firms; and with no up front, maintenance or software upgrade costs, a paperless and scalable platform, EnOC can support the smallest of companies to the largest.
If I could give anyone any advice, it would be to start now if you haven’t already. You must push through the inertia, because the journey of a thousand SM&CR miles begins with a single step.
For more information on the EnOC Pro Platform and its SM&CR expansion, Accountability, visit enoc.pro/smcr