As the industry’s attention remains on the Halloween Brexit deadline, there’s another frightening date which has been flying under the radar.
On the 9th December, the last major aspect of the SMCR falls into place (save for a 12-month transitional period). Given the amount of time banks have had to prepare, one would assume that the SMCR rules are embedded in company culture, but figures suggest otherwise, and banks who fail to prepare risk more than a slap on the wrist. In 2018, there was a 70% rise in FCA lifetime bans compared to 2017. At the same time, the number of FCA investigations into individuals is increasing, as is the number of complaints to the Financial Ombudsman Service – suggesting that consumer concerns are far from eradicated.
It seems that many of the firms subject to SMCR at this stage are still falling short. And December’s deadline is unlikely to mark a change in focus. As the rules come into full force, we can expect the regulator to double down on any firms dragging their feet with SMCR compliance. It’s no longer only UK senior managers who have to worry about personal accountability. Since the SMCR was announced, the world has started paying attention. Several jurisdictions outside of the UK have used this as an opportunity to examine their own actions, and are starting to realise the importance of holding senior managers accountable for regulatory breaches by anyone under their command.