A core aim of the SM&CR is to reduce consumer harm and strengthen market integrity by focusing on people, behaviour and personal accountability.
The FCA will expect firms to embrace the principles of responsibility and accountability, as well as the process for implementing the regime and effectively making it work well in practice on a continuing basis.
The SM&CR principles and rules are designed to shape good culture and represents a minimum standard for the behaviour for those working in financial services.
This means culture should continue to be instilled by the leadership of the firm who are expected to promote consistent standards of good personal conduct for all staff, and set a clear tone from the top.
The FCA believes that a “healthy culture is good for business as well as for consumers and for markets as a whole”, which is a win-win situation for firms.
Firms can promote and maintain healthy cultures by ensuring individuals take on personal responsibility for consumer and market outcomes, by listening to feedback and encouraging individuals to do the right thing and speak up.
As part of the SM&CR, a user-friendly directory will be established in March 2020 for banks, building societies, credit unions and dual regulated investment firms, and for all other firms in December 2020.
The directory is a public source of information which contains information about individuals in key roles who will not be included on the Financial Services Register as senior managers.
It is designed to improve transparency and will enable consumers to verify the identity of certain individuals working in financial services, such as those selling or providing advice on financial products.
The directory will also help firms cross-check references, and is designed to support the FCA, law enforcement, professional bodies and other regulators in monitoring the market.
The aim of the drectory is to provide a more secure system, making it more difficult for unsuitable individuals to operate where they might otherwise engage in misconduct and harm to the market.
Innovation, data and data ethics
In its last business plan, the FCA seemed to be weighing up the benefits brought by technology in terms of improved access to products and services, and improved competition, against potential risks (including, in particular, those related to data breaches and cyber resilience).
The FCA was also focused on how its engagement through FCA Innovate, its sandbox, and other initiatives were helping to upskill the regulator itself.
