Are insurance companies really prepared for the effects of SMCR?
13 Sep 2018
International law firm Simmons & Simmons is today urging the insurance market to prepare themselves ahead of the upcoming implementation of the Senior Managers and Certification Regime (SMCR). The new regime is an extension of the existing Senior Insurance Manager Regime (SIMR) and reflects the regulators’ desire to increase individual accountability for actions within firms. Insurance companies will now have extra requirements to comply with – most notably the need to certify as fit and proper, several staff who might previously have been approved by the FCA.
Whilst the new regime is focussed on individual accountability, insurance firms will equally be expected to account to the regulator for their compliance, including providing training to staff and maintaining a record of supporting evidence, such as regulatory references, criminal record searches and proof of qualifications obtained. An audit trail will therefore be key to successful compliance, however, the amount of documentation required may make this difficult for firms to maintain.
The new requirements provide ample opportunities for mistakes to be made and, with the regulator likely to take a dim view of non-compliance, insurance firms are increasingly asking for guidance on how to implement the new measures. Particularly as conduct rules training for Certification Staff must be completed by 10 December 2018.
Pollyanna Deane, partner at Simmons & Simmons, has extensive experience advising clients on the implementation of the SMCR and noticed that there was relatively little support available for insurers making the decisions and building the framework required under the new regime. She said: “The big question clients have been asking for months is ‘where do we start?’ – a question that doesn’t always have an easy answer – which is why we devised The SMCR Solution.”
Unique in approach, The SMCR Solution enables firms to meet the training obligations as well as the data and compliance requirements of the SMCR. Offering both management and training support, the tool is regularly updated to reflect changes in the law and regulation and can be tailored to suit the needs of a company’s structure.
Speaking about the new product, partner, Pollyanna Deane said: “The SMCR Solution is a unique, flexible product, designed to help insurers with their compliance, training and management oversight as well as with the difficult decisions that need to be made in preparation for the SMCR. The product provides firms with ongoing support, it integrates easily with their own systems, ensuring a smooth and efficient transition to the new regime.”
The tool officially launches on Tuesday 25 September 2018. For a demonstration or for more information, click here.