The challenge

Our client, a leading general insurance firm, wanted extra assurance around its post-implementation SMCR position. Having already invested heavily into getting the business SMCR ready, our client wanted to be sure there were no areas of non-compliance that could unravel all the good work it had already done. But, it was also in the midst of dealing with the fallout of the Covid-19 crisis and simply didn’t have the time or available resource to do this itself.

The solution

First, we took the time to truly understand our client’s business, its commercial drivers and challenges. Then, we designed a review process that balanced this with FCA expectations, taking into account industry best practice.

This included a thorough review of its SMCR arrangements and a remote desk-based review of its documentation – all backed up by video interviews with key stakeholders. We considered:

• How appropriately our client had identified the senior management and certified population, and allocated responsibilities.
• Whether the statements of responsibility and certification process were up to scratch.—The effectiveness of our client’s process for assessing fitness and propriety.
• The effectiveness of the governance arrangements, including oversight, monitoring and record keeping relating to the implementation and ongoing maintenance of the SMCR framework.
• The quality of the scheduled training plan, process and record keeping arrangements for the conduct rules.
• The effectiveness of policies and procedures to assess adherence with the relevant rules and guidance.

Having presented our findings in a high-level written report, we worked collaboratively with our client to discuss the findings and outline improvements that could be made. What’s more, as culture experts, we also provided insight on how they could improve their culture to support their SMCR efforts, taking their approach to the next level.

The TCC difference

• Taking a collaborative approach, we designed a robust but unobtrusive review process that could flex around our client’s busy workload.
• Our regulatory expertise, combined with our commercial approach and industry exposure, helped our client to take action that really made a difference.
• Because we understand the link between SMCR and culture, we identified areas for cultural improvement to support our client’s wider SMCR framework and ensure ongoing compliance.