Normally in this article I focus on a topical issue for our institutional colleagues in the Asset Management, Investment banking and wholesale activities. For this article I’m going to highlight the more human aspect of issues concerning our friends in non-retail businesses.
HR departments and senior staff within them are coming under increasing pressure to support projects across the business and yet few businesses seem prepared to commit and increase HR headcount to assist with this pressure. Generally speaking the continued political uncertainty is producing some inertia amongst senior manager and business leaders. This does not help our friends in HR who are looking at issues of recruitment, relocation due to Brexit concerns or the monitoring of individual accountability due to their inclusion in the SMCR regime, particularly in Investment Banking.
Those caught by Accountability II are like their retail colleagues, just waiting with baited breath for the consultation paper, so its delay is not helping with their planning
Let’s break the burning hot topics down and see where the pinch points might be;
SMCR
Many institutional colleagues have moved across to the new regime and they now face the constant up keep of governance and responsibility maps, responsible recruitment, FIT and check including CRB and credit checks on both new and existing staff. HR areas seem on the whole to be shouldering most of this, including new ways to demonstrate the competence and ongoing development of senior managers. Those caught by Accountability II are like their retail colleagues, just waiting with baited breath for the consultation paper, so its delay is not helping with their planning.
MiFID II
The latest figures show a large number of firms do not believe they will be ready. The pressure to adjust T&C activities for Research and non-advised generic information givers is not helped by the lack of clarity on the COB rules which should cover this as well as client categorisation and other burning issues. The deadline of 3rd January looms large and training plans for staff can’t be planned until some guidance is provided, again something HR departments have been tasked with arranging.
GDPR
Project work on this is underway but HR is being asked to find additional experienced external resource to support firms. There are 90 articles, of which 50 have still to be agreed for the UK. Most firms’ gap analysis will have mapped the 90 articles and highlighted which ones affect them, but in order to get their systems and controls of data management right, will still be a huge task. Of course this includes the data held on employees, which HR departments are being asked some complex questions about, with regards to who sees what and when.
Budget pressures
HR departments are being asked to recruit additional compliance department resource ahead of the fast-approaching project deadlines. Average salaries and pay increases of up to 15% for existing staff is outstripping other areas by some way. Whilst this may seem reasonable as one Head of HR said to me this week. ‘it’s not just Compliance who are providing 2nd line activities, I have to upskill my staff to be 2nd line gate keepers and we are just not getting the support to do that.’
HR responsibilities in Financial Services are changing, they have moved from simple pay and rations to integral and critical business support with many appearing to be buckling under the pressure.