SMCR Critical Success Factors 

Posted on: 25 November 2019

Written by: Kumar Ved

From experience, the following are key to delivering a successful SMCR implementation project:

  1. Setting the tone at the top to embed the right culture adopting the spirit, not just the letter of the regulations

  2. Strong project sponsorship and leadership; competent and capable project teams: combining subject matter and project management knowledge and experience

  3. Early engagement of all those who are impacted.​ Tailored communications are critical

  4. The project scale should not be underestimated, it should be adequately resourced and funded

  5. The burden of implementation will vary depending on the firm’s size and complexity, and regulators expect firms to take a proportionate approach. However the actual activities remain largely the same regardless of the size of the firm

  6. Allocating responsibilities under SMCR has very serious implications and shouldn’t be seen as a compliance boxticking exercise. Can lead to structural and org chart changes

  7. Ownership of SMCR BAU process post implementation should be agreed at the earliest stage

  8. SMCR requirements need to be embedded into business-as-usual and integrated into processes (notably in the HR space); technology needs to support that

  9. Training for all affected staff needs to be meaningful (e.g. Conduct Rules)

If you have any questions or require any support we have a range of specialist services to help you interpret how the regulation applies to your firm and develop a pragmatic approach to implementation and ongoing compliance.


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