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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?​

This template provides the structure against which your senior managers can do just that. The template was developed from real experience from implementing and operating SMCR, including direct regulatory feedback and oversight as we implemented SMCR.​

Documenting your reasonable steps in this way also provides a crucial element of your senior managers handover to a new senior manager. Significantly shortening the effort required for any handover, and enabling handovers to take place even after an individual has left because the corporate memory remains. For the outgoing SMF it means they have a record that provides strong evidence about the boundaries of their personal liability.​

Contained within your digital download are:​

  • A reasonable steps template ​

  • Italicised notes and examples to help guide you through.​

  • Industry standard sections such as skills and responsibilities​

  • Sections which indicate where you need to add individual or company-specific information​

  • Best practice for a SMF​

  • PRA and FCA requirements

Reasonable Steps Template

Excluding VAT
  • This file is in Microsoft Word (*.docx). 

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