Now you might wonder why anyone in their right mind would write about policy. What makes a good policy? Nothing, you might say. Policy is boring, it is irrelevant, it is meaningless, it is dry and it is old-fashioned.
To a point I agree. In the digital age what really is the point of writing out a few tired phrases purporting to be “the way things should be done” to sit in a forgotten corner of the web taking up space and interesting no-one.
Nobody reads it, nobody owns it, nobody updates it, nobody tests compliance against it. It is a hostage to fortune at best, a ticking time bomb at worst. It adds no value, it gives no insight, it does not help. Why bother?
The answer to these valid challenges is: this is the way our policy often is – but not the way it needs to be.
On 7th March 2016 the new regulatory Senior Managers Regime came into force for the UK banking and insurance sectors.
This Blog is a guide to the banking regime (SMR). Many of the same rules are also included in the insurance version of the regime (SIMR) but we concern ourselves here mainly with the SMR.
The SMR replaces the old ‘Approved Persons Regime’ and is the tool now used by the UK regulators – the Prudential Regulation Authority (PRA) and Financial Conduct Authority (FCA) – to assess and approve whether people in key management positions in UK financial firms are ‘Fit and Proper’.
And it reaches far and wide, especially when it starts getting applied to other financial firms (as well as banks and insurance companies) in 2018.
But what does it all really mean and how will it help?