Naturally, the SMR will lead to greater scrutiny of the most senior individuals within firms and their operations on a day-to-day basis.
To support senior managers, a firm needs to establish a framework that allow these individuals to quickly and clearly evidence that they are taking reasonable steps towards fulfilling the responsibilities assigned to their ‘Senior Management Function’.
Likewise, a framework needs to be put in place to allow the firm itself to document that it is routinely assessing the fitness and propriety of its senior managers.
It seems clear then that the roll-out of the SMR will lead to yet more pressure on firms to enhance their reporting capabilities.
The best way that firms can meet these regulatory requirements is by ensuring that the day-to-day operations of the firm, and thus senior management, are brought into formal structures of governance focused on record-keeping and the creation of a clear paper trail to evidence the fulfilment of responsibilities.
Of course, the creation of such a paper trail can be a drain on internal resource, and outsourcing is a prudent choice when it comes to record-keeping.
Some companies offer clients the ability to keep up with increasing reporting requirements with a simple phone call, allowing senior managers to securely dictate and then receive an accurate transcript of their meetings so that their talents can be utilised elsewhere.
Kirstie White is co-founder of VoiceNotes.co.uk