Chris Davies: The unintended consequences of the SM&CR

I have written before about the Senior Managers and Certification Regime (SM&CR) being the most personally impactful piece of regulation to hit retail financial services in decades but what is also apparent is there are some unintended consequences the sector needs to address and include in its implementation processes. *A Hierarchical structure: The SM&CR means it is those who hold a senior management function (SMF) who are the ultimate decision-makers and are required to hold ‘statements of responsibility', one ‘prescribed responsibility' and overall responsibility. As such, firms need...