The Senior Managers and Certification Regime in UK practice and global context

33 Pages Posted: 17 Jul 2024

See all articles by Eleanore Hickman

Eleanore Hickman

University of Bristol

Alan Brener

University College London - Faculty of Laws

Date Written: July 08, 2024

Abstract

Public anger following the 2007/8 financial crisis was exacerbated by the failure to hold anyone to account. A Parliamentary Commission recommended new legislation which resulted in the Senior Managers and Certification Regime (SMCR). A few other jurisdictions (eg Ireland and Australia) adopted similar requirements. In this article we employ empirical methods to assess the SMCR's effectiveness some eight years after its introduction and consider how the regime compares to those adopted elsewhere. Our research indicates a perception that when the SMCR was initially implemented in 2016, regulated firms went into overdrive to make the new regime effective, but that regulatory focus has since moved on. Our participants all appear to agree that the quality of documentation and level of accountability has improved, but the impact on culture and professionalism was more conflicted. On top of this there are specific concerns about regulatory process delays, the provision of references and recruitment and retention. Conversely, the question of lack of enforcement, over which concerns have previously been raised, appears to matter little except in relation to its role as a signalling device.

Keywords: banking, regulation, financial services, senior manager accountability, culture, trust

JEL Classification: K22, D22, G21

Suggested Citation

Hickman, Eleanore and Brener, Alan, The Senior Managers and Certification Regime in UK practice and global context (July 08, 2024). Available at SSRN: https://ssrn.com/abstract=4892679 or http://dx.doi.org/10.2139/ssrn.4892679

Eleanore Hickman (Contact Author)

University of Bristol ( email )

36 Tyndall's Park Road
Bristol, Avon BS8 1TB
United Kingdom

Alan Brener

University College London - Faculty of Laws ( email )

Bentham House
4-8 Endsleigh Gardens
London, WC1E OEG
United Kingdom

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