EVENT: UK Senior Managers Regime: What does it mean for you?
Date: 10th December, 2015 Time: 06:30 pm - 08:30 pm
The ABA's latest technical seminar addressed the new 'Senior Managers Regime' (SMR) being implemented by the UK regulators. The SMR makes senior managers of banks personally responsible for their work and, potentially, personally liable for any failings that they, or those who report to them, make.
UK banks, including branches and subsidiaries of overseas banks, must implement the Senior Managers Regime by March 2016.
The seminar was sponsored by KPMG and Mishcon de Reya, with Simon Hills, from the British Bankers Association, providing an introduction and moderating the discussion.
Giles Adams, a Partner in KPMG’s Regulatory Risk and Compliance Practice stressed the need for Arab banks working in London to be clear about whether responsibility for decisions lay with managers London or with managers in their head offices in the Middle East. When responsibilities lie with head offices, then managers in the Middle East must understand what the regulators in London will expect from them.
Adam Epstein, a partner in the Finance and Banking Group at Mishcon de Reya, explained how senior bank managers must be able to demonstrate to regulators that they have been fulfilling their responsibilities. For example, if a manager is investigating a possible breach of the bank's internal rules, he should make a written record of the investigation that can be shown to regulators if they request it. In simple terms, it is not enough to “do the right thing”, Senior Managers have to be able to show – with documents – that they have been doing the right thing.
Greg Campbell, a Partner in Mishcon de Reya’s Employment Department, described the requirement for banks above a certain size to nominate a senior manager as a “Whistleblowing Champion”. (Whistleblowing” is when a member of staff reports, anonymously, a breach of rules or of ethics that is happening in a company, but which managers are ignoring.)
All three experts stressed that the new Senior Managers Regime, which comes into force in March 2016, makes senior managers personally liable if they do not discharge their responsibilities in the way that the regulators expect.
The presentations given by Giles Adams and by Greg Campbell are attached below. Photographs from the event are posted on the 'Gallery' section of this website.
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