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 templates have been developed from real experience from implementing and operating SMCR in banking firms, some of whom had direct regulatory feedback and oversight as they implemented SMCR.
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. Especially over the extent to which a business facing SMF can rely on a back or middle office function SMF such as client onboarding, operations, IT and HR.
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.
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.
This pack of templates comprises a reasonable steps template plus 11 annexes, covering:
- Statement of Responsibility
- Job Description
- Committee Membership
- Handoff’s (reliance on others)
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 Microsoft Word (*.docx) format. It is also available from our store in Word 97-2003 (*.doc) format.