Arrival in Oz
Having taken the plunge to move from advising at one of ValidPath’s AR firms to a compliance role at ValidPath HQ, I feel like Dorothy getting a peek behind the curtain in the Emerald City. As an adviser, I’ve always been aware that ValidPath did a lot of valuable “stuff”, but it turns out there is much more to running a network than I ever appreciated.
Not that there is an elderly man pulling a lot of levers and shouting into a microphone (although there’s definitely scope in Kevin’s office to install those) but it’s interesting to see the mechanics of what makes a network tick, and in particular, its interactions with the FCA.
Near the top of my to-do list, just below figuring out how to work the coffee grinder, is the job of getting to grips with the implementation of SM&CR. Now I’ll be honest – as an adviser, given that ValidPath has always followed that acronym with “this is not a matter that our Members need to worry about”, not only had I not worried about it, I hadn’t even taken the time to properly understand what it was. Well, that’s all changed now, and I am gradually ploughing through telephone directory sized FCA missives on the subject. As it turns out, SM&CR is a really big deal and one that’s going to take up a good chunk of my time between now and Christmas.
SM&CR, or the “Senior Managers and Certification Regime”, seeks to make senior individuals in the finance sector more accountable to the regulators, involving a significant shift in responsibilities for senior management, and considerably more stringent procedures applicable to all staff. It’s difficult to argue against the fact that such a move was much needed following the banking crisis, and the regime change was implemented for the banks over three years ago.
In December 2019, SM&CR will be rolled out across the remainder of the industry with one key exception. While all networks and directly authorised firms are having to get their heads round the new regulations, luckily for our Members, the new regime does not apply to Appointed Representatives. This means that while at ValidPath we have procedures to write, responsibilities to allocate, and staff training to undertake, our Members are free to go about their business without any such upheaval.
We may not have levers and microphones, but there’s an awful lot going on behind this curtain that as an adviser I never saw, and quite rightly so – as it says on our SM&CR introductory page, ValidPath handles these things so that you don’t have to. But now that it is my responsibility to deal with these matters, when the implementation deadline of 9th December lands I might just treat myself to some sparkly red shoes.