Reasonable Steps Under the SMCR - What the Regulator Expects

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 practical, live and interactive virtual classroom seminar explores the regulatory expectations, judgements and behaviours that underpin the reasonable steps obligation. Moving beyond the rules themselves, it examines how Senior Managers can demonstrate effective oversight, challenge, delegation and follow-through and how to evidence the steps they have taken to discharge their responsibilities.

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.

Whether you are new to a Senior Management Function (SMF) or an experienced Senior Manager looking to challenge and strengthen your existing practice, this session will help you to focus on what matters most: not simply whether you took action, but whether you took appropriate steps, at the right time and can demonstrate why they 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.