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Around 47, additional financial services firms andindividuals are likely to fall within the scope of SMCR. Whilst implementation may be a challenge for some firms, those firms that take this opportunity to enhance their arrangements will be in a position to better serve consumers, capital markets and their employees.
Several key concerns, of the asset managers we spoke to, include: Proportionality Firms have stressed the need for proportionality. Other firms with many legal entities may sit between core and enhanced requirements, which adds complexity.
But overall there was concern about whether core and enhanced offered enough scope for proportionality. Parallel regulatory concerns The complexity of dealing with a number of regulations at the same time was a key concern for many across the sector. Allocation of the right Senior Managers Some firms considered an undue weight in the core regime on control, rather than versus business accountability, where the risk taking is owned.
Firms were concerned that some senior management, responsible for risk taking decisions, will not be within the core regime as Senior Managers. Retention risk A number of firms were having difficult conversations with individuals who may be impacted by the regime.
The challenge for firms is to provide these individuals with enough ongoing advice and support. Firms are not clear on what this means and what changes may be required within existing product governance processes to accommodate this. Having worked with numerous Banks to respond to and implement the SMCR, KPMG believes asset managers should seek to learn from this experience and see this as an opportunity to bring about positive cultural changes to the way in which they conduct their business.
Done well, the SMCR can genuinely improve the effectiveness of how a firm is organised and governed in addition to improving accountably across the firm. Although the deadline for implementing the SMCR has not yet been set, our experience of working with banks shows how vital it is to be proactive in ensuring firms are set up correctly to manage the transition.
How KPMG can help? Please contact us to find out more.Elaghmore Partners is delighted to have been named as small private equity firm of the year at the ACQ5 Global Awards ACQ5 is the leading corporate news magazine in the private equity sector.
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