FSMA requires all individuals within the Senior Manager Regime to take reasonable steps but what is reasonable and how do you go about proving that what you have done is reasonable? The best approach is to start by documenting how you go about doing your day to day job, who you rely on, the assumptions that you make about what others are doing on your behalf, and how you exercise oversight. This enables you to operate as normal making note of the exceptions and material issues.
This is not just one template, it is a comprehensive series of 12 templates developed to take into account regulatory expectations, best practice and what is realistically practical and proportionate to document. The process of populating these templates always prompts highly productive internal discussion about the split of responsibilities amongst senior managers, and senior management more broadly.
An additional benefit from having completed all these templates is that they can form part of a senior managers handover to a new senior manager. This can significantly shorten the effort required for any handover, and also enable handovers to take place even after an individual has left because the corporate memory remains. For the individual senior manager, they can retain their own personal copies of the completed templates thus protecting themselves in future.
These have also been shared with the regulators when senior managers or the firm is asked about a specific aspect of a role or about implementation of the SMR more generally.
This pack of templates includes:
- Reasonable steps
- Statement of Responsibilities
- Job Description
- Handoff’s (reliance on others)
These templates are intended to be relatively self-explanatory but there are italicised notes and examples to help guide you through. Most of the content can be assembled by support staff although comparing content amongst all Senior Manager Function holders can be extremely productive and ensure that any assumptions are clarified and any over or under laps identified. The document is 18 pages long. The template avoids use of regulatory jargon and legal terminology.
The template enables you to apply your own firm's branding and inhouse terminology as it has in plain background and black and white.
We also provide a Senior Manager training pack in the shop that supports implementation of this framework.
Reasonable Steps Templates
This file is in Word 97-2003 (*.doc) format. It is also available from our store in Microsoft Word (*.docx) format.