Jo Geraghty


The Senior Managers Regime

Date added: 10th Mar 2016
Category: Culture of conduct/ethics

On Monday 7th March the financial services sector saw the start of a seismic change which by the end of 2018 will affect everyone who has a bank account, investments or insurance. So far the change has given rise to countless hours of planning, reviewing and no doubt soul-searching as those affected by the first wave drew up management responsibility maps, identified key individuals and completed registration or grandfathering applications.

If you’re in the financial services sector you will probably be well aware of the senior managers regime (SMR); but it’s fair to say that the average person in the street could well be forgiven for being less well informed. And to be quite honest, even if they are aware of the new regime they may well be slightly sceptical. After all, the reputation of the financial services sector has taken a battering in recent years so why should ‘a new piece of paper’ change culture and attitudes?

Well let’s start with what the SMR is meant to achieve and where better place to start than a recent PRA publication which summarised the new regime as “aimed at supporting a change in culture at all levels in firms through a clear identification and allocation of responsibilities to individuals responsible for running them.”

This gets right to the heart of the change. The senior managers regime is not some form filling exercise, nor is it a time taking paper chase as key individuals are recertified every year. In a way, these processes are merely a means to an end and that end is no more and no less than a complete culture change which moves the financial services sector away from the toxic practices of the past. Skim publications and speeches from the regulators over the last couple of years and this desire for change becomes abundantly clear. Doing things right, fitness and properness, customer focus and above all culture change appear time and time again.

But culture will only change when those in a position of leadership demonstrate the new culture through their every action and decision. The recertification regime will only be effective when those who are responsible for carrying out reviews put values and ethics and customer focus ahead of short-term profitability. The first time that an individual is ‘ticked through’ simply because of their contribution to the organisation is the first nail in the coffin of yet another failed initiative.

Should consumers be sceptical; well at the moment we would have to say that the jury is out. Changing toxic cultures and attitudes is no easy task. On the other hand, if the initiative succeeds in driving culture change throughout the financial services sector then we should quickly start to see a self-feeding spiral of organisational culture improvement. As cultures and attitudes change customer satisfaction and reputation improves, new customers are attracted and this drives increased profitability. This then feeds back into organisations which are driven to further improve customer focused cultures and so on.

It’s not much to ask, that those who are ultimately responsible for the financial wealth and prosperity of our country “focus on the concepts of acting with integrity; skill, care and diligence; and regard to the interest of customers – as well as on being open and cooperative with regulators; and observing proper standards of market conduct.” Let’s hope that the senior managers regime lives up to its promise and finally delivers a culture change which will deliver good, ethical and strong financial services for all.


Leave a Reply

Your email address will not be published. Required fields are marked *