Reasonable Steps Under the SMCR: An Advanced Masterclass in Judgement, Oversight & Evidence

Introduction

What does it mean to take reasonable steps when responsibilities are complex, information is incomplete and competing priorities demand difficult decisions - and how can you demonstrate that your approach was reasonable?

This advanced, live and interactive masterclass builds on an existing understanding of the Senior Managers and Certification Regime (SMCR) to explore the judgements, behaviours and evidence that underpin effective Senior Manager accountability.

Moving beyond the rules themselves, the session examines how to exercise effective oversight, challenge assurances, delegate appropriately and ensure timely escalation and follow-through. It also considers whether the records supporting your decisions and actions would stand up to subsequent scrutiny.

Through practical case scenarios, facilitated discussion and real-world challenges, participants will test their existing approach, examine common areas of exposure and consider how to respond to missed warnings, control failures and emerging issues.

Designed for Senior Managers and experienced compliance, risk and governance professionals, this masterclass will help you critically assess whether you are taking appropriate steps, at the right time - and whether you can demonstrate why those steps were reasonable.

What You Will Learn

This live and interactive course will cover:

• Regulatory expectations
• What FCA and PRA guidance, rules and enforcement cases tell us about reasonable steps
• Where Senior Managers are exposed
• Common weaknesses in oversight, delegation, challenge, escalation and decision-making
• A practical framework for taking reasonable steps
• An example approach to identifying, implementing and reviewing the actions required to discharge your responsibilities
• Evidencing reasonable steps
• What credible evidence looks like and how to demonstrate the rationale behind your decisions and actions
• The overlooked risks
• Common gaps between what Senior Managers believe they are doing and what their records, behaviours and oversight arrangements actually demonstrate
• When things go wrong
• How to respond to emerging issues, missed warnings, control failures and regulatory scrutiny, including what to do next and what to learn from the experience

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.