SMR: Assessing Fitness and Propriety

As the Regulators implement more and more legislation to ensure that individuals are personally accountable for their actions, managers within firms that are responsible for and/or involved in the process of assessing and evidencing the Fitness and Propriety of others need to be better informed.

The new Senior Management Regime brings not only increased potential criminal sanctions  at an individual level, but also the introduction of the “Presumption of Responsibility” which will exist from March 2016.

Firms need to be sure that those individuals holding an SMF or Certification function are truly “Fit and Proper” for the role which they will undertake.  Part of that process is for those involved and/or supporting the assessment of individuals as ‘fit and proper’ to be very clear on what is required by the regulators, and what controls  and record keeping must take place as a minimum.

This workshop has been designed to support HR professionals in navigating the new regime.  It will enable you to address immediate strategic considerations, and potential red flags,  that may arise around systems and processes, appraisals and performance management, supervision, training and compliance.

Attending this BBA workshop will enable you to:

  • Be clear on what the F & P requirements are under SMR
  • Understand the different F & P requirements for an SMF versus an individual that is caught under the new Certification Regime
  • Consider what F & P means in practice and what this translates to in terms of processes and record keeping requirements
  • Understand that F & P is not something that is evidenced just at the outset of an individual undertaking a role
  • Clarify the regulatory source books that drive F & P requirements and what the rules  that must be adhered to
  • Be clear on the role that HR and other relevant support functions will have on the F & P for individuals within their firm

The new Senior Managers Regime

  • An introduction to the new regime
  • Why it is being introduced
  • What does F & P mean
  • How does it impact the individual


The new regulatory rules governing people under SMR

  • The rules applying to different roles – SMR versus Certification Regime
  • The regulatory rules versus employment law
  • The development of the concept of SMR’s, their recruitment, fitness and propriety
  • The high level standards
  • Who is responsible within a firm for F & P of individuals


The importance of fitness and propriety

  • The contents of the FIT sourcebook
  • The standard of suitability
  • How to decide what vetting standards to apply
  • The role of HR as the overseer of Fitness and Propriety
  • When an individual’s F&P is in question
  • But what about those already in post


Senior management arrangements, systems and controls

  • The contents of the SYSC Sourcebook
  • What key controls should you have
  • Record keeping
  • Identifying, managing and reporting breaches


Principles and Code of Practice

  • APER – Principles and code of practice
  • Examples of improper behaviour
  • The culpability standard
  • Trends and latest information on enforcement actions
  • How will you ensure that your individuals meet and adhere to the regulator standards required of them

Registration: 09:00
Start: 09:30
Close: 17:00

Lunch will be served and there will be two 15 minute breaks (mid-morning, mid-afternoon).

* Please note that the programme sequence and/or subject matter may differ from what is presented herein; the programme is constantly being updated to embrace new ideas and developments – as they evolve.

BBA Trainers use a blend of presentational methods in order to assist in a delegate’s understanding of the workshop content; where applicable and possible, the workshop is enhanced through the use of group exercises, role play, and case studies.

Lorraine Mousley

Lorraine has 32 years’ experience in financial services, 26 of which were gained at a major international banking group. Most recently, Lorraine has been advising firms and individuals on how to meet their regulatory responsibilities in areas such as training and competence, approved persons and retail conduct risk.


Lorraine has over 27 years’ experience in the Financial Services Industry, primarily within a large international Bank Group giving her a wealth of knowledge to draw upon. Holding the position of Area Sales Manager for 9 years has provided Lorraine with an excellent grounding in dealing with a diverse audience and capability levels, whilst also enabling motivational and training skills to be fully developed.


In addition, Lorraine has experience as an Independent Financial Planner, so can also relate to the working environment of both employed and self-employed individuals, and can cater her style to facilitate any learning environment or individual style. As a Chartered Financial Planner, Lorraine was also one of the first two people in the country to have fully completed the CII Regulated Diploma. Lorraine has extensive training experience at Regulated Diploma level, across all subjects, and is an Accredited CII Trainer. With her comprehensive technical expertise Lorraine is ideally placed to deal with CII Regulated Diploma examinations.


Most recently she has supported clients with audit based reviews of client files, recommendations and advice given to ensure these meet the regulator guidelines and firm specific best practice.

Take this workshop in-house

If you have five or more delegates who wish to attend this course, it may be more cost effective to run it in-company. To find out more about in-company training, please contact Philip Allen Director of Learning on 0207 216 8843 or