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Employing competent staff should be the Number 1 control in your ‘first line of defence’.

Competence is not an opinion, it is a measurable standard.

The challenge for firms is defining, measuring and demonstrating the competence of their employees.


First things first. If your firm doesn’t have a written policy, framework or process around Training & Competence (T&C) then you have a significant exposure to regulatory risk. If you have documented T&C governance arrangements, you need to ensure that the key elements used to demonstrate competence are role specific and measurable.


Being competent is not an opinion; it’s a demonstrable standard of knowledge, skill and aptitude for a given role. You need to be able to demonstrate that competence is clearly understood and measured consistently.


This is relevant to everyone within scope of the Conduct Rules, not just SMFs and Certificated staff.

“We will increase our supervisory focus on the Conduct Rules. We expect all SMCR firms to ensure that they are embedding the conduct rules in their businesses to meet their obligations under the regime” FCA.

SMCR is “Live”! But many firms continue to be daunted by its perceived complexities, particularly as the repercussions for getting it wrong are potentially so severe.


As we move towards the 9 December 2020 a focus has to be on how your firm will be able to demonstrate the competence of its SMF’s and Certificated employees. You must ensure that your firm is able to respond with confidence should the FCA ask for it to provide evidence of Training & Competence arrangements. Your T&C governance documentation must be complete, up to date and contain objective standards of role specific competence that can be backed-up with hard evidence.


The banking sector has been subject to SMCR since 2016, so we have supported numerous firms through implementing and embedding the Regime in the last 5 years. Many of these would admit that they did not allocate sufficient time, or resource to getting SMCR implemented within the given timeframes.

So the key message is:

Do not under estimate the amount of effort that’s still required to be ready for 9 December 2020.


If you’re looking for reassurance that your implementation of the Senior Managers Regime and / or the Certification Regime is being done properly, you are not alone.


We can provide you with as much or as little support as you need.


Contact us to discuss our unique Culture Assessment Process and any other support that will be of benefit to you and your firm.

To discuss next steps, please call us today on 0203 178 4230. Or email apprenticeships@fstp.co.uk.

Please get in touch today. We’ll quickly discuss the challenges you’re facing and explain how we can help you.

0203 178 4230


What we can do;


  • Review, or draft, a T&C policy framework to ensure it includes all key milestones e.g. recruitment, induction, attaining / maintaining competence, supervision, CPD etc.
  • Ensure specific competencies are well documented in role profiles.
  • Ensure the competence standards are quantifiable and role specific.
  • Assess the robustness and rigor of supervisory arrangements including supervisor competence, support mechanisms e.g. appraisals etc.
  • Ensure that Key Performance Indicators and Key Risk Indicators are defined and reported through meaningful, timely and accurate Management Information.
  • Create and deliver bespoke training and developmental solutions to close identified gaps.

Highly experienced consultants

We only provide sector specialists with experience at the highest levels in the industry. And with our finger constantly on the regulator’s pulse, you can expect knowledgeable and up-to-date advice.

We’re always easy to work with

This is often underrated, but it makes a difference. We quickly get a feel for your firm, working with not against your team. It means we get the job done without friction and without fuss.

Advice tailored to your business

You need consultants that get your business, not just financial firms in general. So we first understand the specific needs and nuances of your firm, resulting in more relevant, practical and effective support.