This browser is not actively supported anymore. For the best passle experience, we strongly recommend you upgrade your browser.
| less than a minute read

SMCR Reasonable steps - simple in theory, challenging in practice

'Reasonable steps' has now become a part of the vocabulary of the regulators and senior managers alike.  But what may appear to be a relatively simple concept can be extremely challenging in practice - both in terms of a senior manager establishing a 'reasonable steps' framework and in demonstrating that a senior manager took reasonable steps when things may go wrong.  

To read more about 'reasonable steps' and how you evidence them see our latest Risk Advisory blog post here.

As highlighted in a recent speech by Mark Steward (Director of Enforcement and Market Oversight): “implementing the [senior managers regime] has meant firms have built into their systems explicit reasonable steps to prevent non-compliance. This has required an assessment of what may make a particular control system or function more vulnerable to failure because it is in those places that the senior manager’s reasonable steps need to be particularly evident.”

Sign up for real-time updates on the latest ESG developments, delivered straight to your inbox - subscribe now!

Tags

smcr, smcrmanager, fca, reasonable steps, reasonable steps defence, risk advisory, corporate governance, accountability, financial services