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SM&CR Series Insight 3: Employee SM&CR Compliance

The aim of this post is help you, an employee of an insurer, to be aware of the Conduct Rules and provide some practical guidance on complying with them. Your employer is responsible for providing you with training and making you aware of the Conduct Rules. Your employer is also responsible for ensuring that the […]


SM&CR Series Insight 2: Senior Manager SM&CR Compliance

The aim of this Insight is to breakdown the Conduct Rules for Senior Managers, who are the most senior people in your company and have the greatest potential to harm market integrity. Rule 1: You must take reasonable steps to ensure that the business of the firm for which you are responsible is controlled effectively. […]


SM&CR Series Insight 1: Employee Oversight

Insurers, get ready to put your governance under the microscope. The Financial Conduct Authority (FCA) will be extending its Senior Managers and Certification Regime (SM&CR) to the insurance industry by the end of 2018. It will replace the Senior Insurance Managers Regime (SIMR). Compared with SIMR, SM&CR will challenge insurers to think more critically about […]


Operational Resilience – SKT Consulting in CityAM

It was great to see that an opinion letter submitted to CityAM by one of our Directors, Mark Rees, was published in the paper on Friday 10th August 2018. It covered operational resilience, and we hope it encouraged debate and moves resiliency up the agenda. You can find Mark’s letter on page 12 of the […]


Moving operational resilience up the agenda

I have witnessed an operational resilience team convene without its chairman, a divisional head shouting for a service to be recovered immediately and a COO stamp their feet. Consequently, I read with keen interest the discussion paper published by the FCA, BoE and PRA on operational resilience. The approaches I’ve seen to operational resilience range […]