Senior Managers and Certification Regime
UK regulators have taken significant steps to improve the culture and behaviours in banking, by introducing a new accountability framework. It contains three components: the Senior Managers Regime, the Certification Regime and the Conduct Rules. This establishes greater individual accountability, starting with Senior Management and moving on to staff at all levels.
Individual Accountability
Relevant senior individuals are required to understand and appropriately oversee their organisation’s trading-related activities.
The Senior Managers Regime is underpinned by a statutory duty of responsibility in which relevant senior bank executives and certain non-executive directors are required to demonstrate that they took "reasonable steps to prevent regulatory breaches in their areas of responsibility".
Technical Practitioners
FMCR Health Check is conducted by a team of experienced technical practitioners selected for their expertise in the specific asset classes and functions most relevant to the client.
The Health Check is designed to complement the work undertaken by Internal Auditors and other functions such as Compliance, Risk and Finance.
Additional Confidence
FMCR Health Check is a forensic tool which provides additional confidence to senior executives that the trading activities’ framework is robust and fit for purpose.
It is designed to be a rigorous and probing examination of the organisational supervisory structure and practices and processes of the trading and sales environment, either holistically or targeted to specific areas.
Analysis and Insight
The analysis of responses to carefully selected questions by the FMCR team provides insight into a variety of Front Office aspects including the cohesiveness and comprehensiveness of the operating model, the robustness of the infrastructure, and the connectivity between trading-related functional units.
Findings and observations are promptly communicated to senior management.