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?
Good documentation still matters for firms in the financial sector in this online age. This blog explains why.
There is so much more riding on it now. More complexity to explain. More choice for the consumer to get her head around. More personal accountability for executives, non executives and public officials.
More risk, more threats, with more potency, that governments, regulators, firms and consumers need to understand and mitigate.
Clarity is the key to that understanding and mitigation.
Good documentation delivers the clarity we need to make the right choices and navigate the complexity.
This blog tries to answer some very simple questions on what banks do and why; and what those of us involved with bank capital, regulation and governance actually do all day; and why.
This doesn’t just mean high street banks but the broad definition of bank: wholesale banks, brokers, investment firms, funds, advisory boutiques, etc.
One way or another they’re all doing intermediation between people who need capital and people who supply capital. Which in economic terms is what it’s all about.
There are huge simplifications in this story but I hope you will bear with them. It is based on an imaginary conversation with an inquisitive pre-teen who I bet now wishes he had never asked the question…