The potential impact of SM&CR is far-reaching. It’s a huge change that will require a lot of careful planning time and resource.
But even the best laid plans run into difficulties.
Although SM&CR is a replacement for the current Approved Persons Regime, it requires a completely different mindset and approach. It’s likely to demand a number of changes to operational infrastructure, policies and processes. But such wide-reaching change can’t happen overnight. There’s no magic switch. It will take time to implement.
With just over 3 months to go, the clock is ticking, and your plans should already be underway. With the deadline of 9th December 2019 looming large, your SM&CR implementation project should factor in contingency time to make sure you’re fully prepared.
SM&CR involves departments all over an organisation, not just compliance. So communication is key to guarantee you’ve considered all business functions, from the Board down.
You may need to factor in additional time to consider these things:
- HR processes – Potential changes to contracts, job profiles, training content, performance management framework, as well as the possible tension between SM&CR and employment legislation.
- Record keeping – Additional accurate and up-to-date records to evidence compliance with the new regime.
- Governance – The impact on corporate governance arrangements, particularly for group and branch networks.
- Regulatory references – Longer lead times as part of the recruitment and selection process to allow for regulatory references to come through.
- Annual certification process – The introduction and application of an effective certification process.
- IT systems – The design or redesign of IT systems to help support SM&CR compliance.
It’s crucial that you fully understand the time and resource required to support your implementation project. There’s a very real chance of lost opportunity if you fail to build contingency into your plan – time that allows you to manage any barriers or delays in delivery.
Evidence from the banking sector implementation back in 2016 suggests that implementation can take longer than predicted.
So what do you do?
- Give your organisation a ‘go live’ date that’s ahead of the implementation date.
- Build in contingency time to account for unexpected delays or issues.
- Get started now to uncover the unknown issues and unforeseen consequences. Ensure that you allocate the right resources to make your SM&CR implementation a success.
Make the most of external consultants early on. When you work with us at TCC we can provide guidance, advice and insight to help support your implementation project. We can also help you to see the bigger picture and spot challenges and weaknesses well ahead of the 9th December deadline.