SM&CR – Tick Box Exercise or Foundation for Cultural Change?


FCA solo regulated firms are now completing the transition of SM&CR requirements into ‘Business as Usual’ but what exactly does this look like?

As this transition continues, knowingly or not, firms are moving to a position where, at one end of the spectrum, SM&CR becomes the foundation stone of lasting cultural change or, at the other end of the spectrum, SM&CR defaults to another ‘tick box’ exercise.

Led by Jeff Abbott of T-CNews and Emma Howell of Worksmart, the webinar addressed six searching questions that enabled delegates to ascertain where on the spectrum their firms are heading.The questions covered aspects including:-

  • The impact on customer outcomes
  • The cultural connection
  • Embedding the code of conduct
  • Consistency and reliability in competence assessments
In answering these questions we considered the impact of such things as:-
  • The 5 conduct questions posed by the FCA
  • The PRA staff working paper no 912
  • FCA Consultation Paper CP21/13 A New Consumer Duty
  • FCA expectations of Fit and Proper Assessments and Code of Conduct

The webinar
This webinar was held on 9 June.

The results of the questions were informative and illuminating providing a clear indication that many firms still had some work to do.

During the first part of the webinar the question of what ‘business as usual’ looks like and how much resource will be needed to stay of top of the regulatory requrements. We also considered whether a regtech solution should be required.  The key points that arose were that:-

  • There are many elements that need to be covered
  • The amount of resource depends on the nature, complexity and activity of your business
  • This is not a one off exercise; it is something that you need to address year in year out
  • Regulatory returns form part of the unobtrusive indicators used by the regulator to measure culture

Before looking at the six searching questions we examined evdience to give an insight into the ‘direction of travel’ of the regulator.  I doing so we picked up on elements that covered:-

  • The addition of a prescribed responsibility relating to culture
  • The feedback from the regulator in the stocktake report published in August 2019
  • The latest messages from the regulator contained in their monthly, regulation round up
  • The positive and negative indicators relating to FIT assessments and Code of Conduct
  • The publication of the consultation paper on ‘A New Consumer Duty’

Six seaching questions were then examined to give the audience the opportunity to decide how well they have performed in developing a solid foundation for cultural change.  The format of the webinar ran through aspects that should be covered off to create a solid foundation as well as tell tale signs that you have created a tick box approach that the regulator wishes you to avoid.

At the end of each questions delegates were invited to answer a poll question to comment on their position as to whether they had:-

  • Solid Foundation (All points covered)
  • Good Foundation (some work to do but not tick box)
  • Weak Foundation (Some Tick Box issues to address)
  • Tick Box  – (Too much focus on just dealing with the immediate rules and tasks)

The results of the questions were informative and illuminating providing a clear indication that many firms still had some work to do. The majority of the results were categorised in the Waek/Good Foundation area.  Why not look at the video and see how you get on?

View the webinar
To view the video please Click Here

Video Duration 73 minutes

What do I do if I need help?
If you would like to see a demonstration of Worksmart’s multi award winning regtech solution, Accord please email  Emma Howell at

If you have questions relating to the content of the six searching questions or need some assistance in helping address any of the issues these throw up please contact Jeff Abbott

Find out more about 2bedvelopment Consultancy


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