Paradigm Consulting's Graeme Stewart looks at the emphasis on 'reasonable steps' under the senior managers and certification regime.
As the Brexit drama unfolds, what steps do advisers need to take now, particularly in light of passporting and advising clients in Europe?

Graeme’s financial services career spans over 30 years, with the vast majority of that time spent in compliance and training and competence roles.

He was one of the first members of the team to join Paradigm when it launched 12 years ago. In that time, as both a partner and head of consultancy, he has been instrumental in building Paradigm’s consultancy service, managing and leading a team of consultants who assist a wide range of financial services businesses across the UK.

This article is for firms to consider what actions they could take now, in order to be ready for the senior managers certification regime to come into force in 2018.

Overview

The FCA senior managers certification regime consultation paper (SMCR) is expected this month (May 2017). Following the consultation, the final paper will be published in anticipation of the new rules, which are expected to begin in mid 2018.

We expect that the ESMA guidelines for the assessment of knowledge and competence will become rule requirements starting from 3 January 2018, as part of the overall MiFID II regulations.

While only 12 pages in length, the paper outlines what Paradigm considers to be a ‘step change’ in the way advisers and staff within a firm demonstrate and evidence their competence to undertake their role.