Preparing for the Accountability Regime

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With the commencement of the new Accountability Regime now less than six months away, could the response of the training industry to the T&C needs make-or-break how prepared firms are by the deadline? Mark Jones from Unicorn Training explores this issue

Would you apply for a job if the ad didn’t explain what you would actually be doing?

Very few of us would.

Yet a significant proportion of regulated businesses have not previously been placing the same value on having robust role profiles in place for people employed by them even though the principal is exactly the same.

With the arrival of the Senior Managers Regime, Certification Regime and new Code of Conduct within the FCA’s overhauled regulatory framework – now coming into effect in less than six months’ time – overlooking the importance of role profiles in accountability is no longer an option. Evidencing is everything.

Role profiles are just one element of T&C that is under the spotlight as that 7 March 2016 commencement date looms ever closer.

Encouragingly the sense is that, throughout the industry, the approach to assessing the impact of this new Accountability Regime seems to have been viewed as an opportunity to look at compliance in the context of cultural transformation with reviewing and refreshing its T&C practices a key component of this.

But having the will to do this, and actually having the time, tools and knowhow to put the right systems and the best practices in place within the ever-decreasing timescales are two entirely different things.

“All firms, depending on size, number of employees, existing policies and procedures etc, will have varying challenges in meeting the deadlines,” acknowledges Mark Jones, Commercial Director, Unicorn Training.

“But the one thing everyone has in common is the need for robust performance management and workflow systems, where recording, file checking and reporting against your firm’s T&C scheme is as effective and accessible as possible.

“Everybody knows the FCA’s bite has matched its bark so far, therefore as the new regulation around accountability comes into effect, being able to show the clear lines of reporting, roles and responsibilities, and producing evidence of competency within the wider context of compliance with the Accountability Regime is critical.”     

Getting to grips with who’s doing what and why


Earlier this year Unicorn joined forces with leading financial services consulting and training specialists, FSTP, to bring a more targeted and streamlined approach to T&C and compliance for FCA regulated firms.

At November’s CISI Training and Competence Conference 2015, the two are co-delivering a workshop on ‘Role profiles – building the T&C foundation’, taking firms through career journey scenarios including recruitment, performance reviews and appraisals, assessments, rewards, disciplinaries, grievance, etc, and highlighting where and how role profiles should be a key document in their processes.

“Role profiles are an integral part of what we do and how we do it in financial services,” explains Philippa Grocott, one of the founding Partners of FSTP. “They should set out competencies and form a central part of a job spec.

“But in our experience of working with regulated firms, all too often we have found, in the worst case scenarios, job roles don’t have a profile, or they are out-of-date, incomplete, or bear no resemblance to how a particular job has evolved over time.

“Especially with the introduction of Statements of Responsibilities, including Prescribed Responsibilities / Additional Responsibilities, and Certified Persons under the Senior Managers Regime, updating and/or putting in place role profiles is key.

How do you effectively undertake a statement mapping exercise if you don’t have a starting point? What is already a huge task almost becomes impossible.

“There is nothing specific laid down in the regulation that you must have a T&C scheme including robust role profiles, but, if you don’t, how do people know what to do and how can accountability be managed? It’s a very necessary requirement but when did you last do an overall assessment of the robustness of your role profiles?”

Robust role profiles give firms a starting point for the whole range of T&C procedures, for example, one-to-ones and performance reviews and assessing what someone does against competencies detailed in the profile to producing questions for job interviews set against the competencies that candidate needs for that role.

So how can you achieve this?

The bigger T&C picture


With deadlines so tight and with many firms still with so much to do ahead of March, having the right tools to speed up the process is becoming increasingly important.

A firm’s T&C scheme provides the basis from which to review and monitor competencies through one-to-ones, file-checking, observations, performance reviews etc.

But streamlining these processes, which can often be disjointed and disparate, and having effective workflow systems to log outcomes, evidence competencies and provide a platform for ongoing monitoring and reporting against that TC scheme should be a no-brainer for senior managers with the FCA watching them like hawks.

The Accountability Regime leaves no hiding place in the FCA’s over-riding aims of raising standards and restoring public trust and confidence in the regulated sectors.

Having access to something like a range of T&C template forms, including for role profiles, could be a Godsend to firms scratching their heads at where to start or even for those who just want to make what they already do easier and more transparent.

Templates are just one element of T&C that Unicorn with FSTP have embedded into their comprehensive compliance solution ComplianceServe to help firms better manage and report around their T&C schemes.

The end-to-end training delivered through the online platform not only includes templates and a range of other useful forms, but also a diagnostic assessment tool to identify gaps in knowledge and ComplianceServe’s comprehensive content catalogue to help fill these knowledge gaps or refresh learning when it is felt to be required.

With time of the essence, there is a real demand for ‘snackable’ T&C and just-in-time and role relevant learning delivered online that not only embeds the core knowledge in line with the new FCA regulation amongst staff, but also heightens awareness of the implications of staff going off track in encouraging genuine behavioural change.

Meanwhile FSTP continue to deliver complementary face-to-face training for more senior roles and/or those requiring highly complex and/or specialist knowledge.

As Mark concludes: “You could argue that we are starting to see more of a crossover between the traditional roles of risk and compliance teams and those in training and competence as whereas compliance is where the focus around conduct and behavioral and cultural change has been centred over the past few years now robust T&C practices are extrinsically tied in with that. You can’t have one without the other.

“The Accountability Regime leaves no hiding place in the FCA’s over-riding aims of raising standards and restoring public trust and confidence in the regulated sectors.

“But the by-product is firms, almost by default, will have to adopt much more commonsense, transparent people management practices. How the training industry supports this could make-or-break how prepared a firm is for 7 March 2016.” 

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