Course Code

  • 1911TRS


  • Taking Reasonable Steps
    26 November, 2019
    10:00 am - 12:00 pm


  • City of London

CPD Credits

  • 2
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Or call 0203 178 4230 or email today.

Course Overview

The term Reasonable Steps is used in the first 3 SMF Conduct Rules:

  1. You must take reasonable steps to ensure that the business of the firm for which you are responsible is controlled effectively
  2. You must take reasonable steps to ensure that the business of the firm for which you are responsible complies with relevant requirements and standards of the regulatory system
  3. You must take reasonable steps to ensure that any delegation of your responsibilities is to an appropriate person and that you oversee the discharge of the delegate’s responsibility effectively.

But what does the regulator mean by the term ‘reasonable steps’?

The Culpability Standard states

“A person will only be in breach of any of the rules in COCON where they are personally culpable. Personal culpability arises where:

  • A person’s conduct was deliberate; or
  • The person’s standard of conduct was below that which would be reasonable in all circumstances”.

Do you or your Approved Persons (SMFs) understand what is expected of you in your execution of reasonable steps? 

The aim of this 2 hour workshop is to unravel the confusion that lies around “reasonable steps” and shed light on the regulators expectations.

Providing sufficient evidence to the regulator that you have taken all ‘reasonable steps’ is vitally important

By attending this workshop you will be able to:

  • Gain awareness of the type of evidence the regulator expects to see
  • See examples of reasonable steps aligned to Prescribed and Other responsibilities
  • Understand when the requirement to take “extra notes” might arise
  • Clarify the need for evidence post leaving a senior management function role

The Course Agenda

Regulatory requirements

  • Clarify The Conduct Rules – A recap
  • Understand the relationship between Prescribed responsibilities, Statements of responsibility and Reasonable steps


  • Appreciate examples of reasonable steps documentation
  • Establish what counts as evidence


  • Confirm when, what and how you may need access to evidence once you have vacated the role
Download PDF Get this course in-house

Or call 0203 178 4230 or email today.

Meet The Tutor

Lorraine Mousley

Senior Associate

Lorraine brings over 30 years of experience in the retail banking and financial advice sector, having worked predominantly in the Banking, Bancassurance and Independent Financial advice sector. Lorraine has extensive experience in all aspects of retail financial services, and a highly successful track record as a Financial Adviser, Area Manager and Training Design and Delivery Consultant. This gives her strong customer focus, employee engagement, and business awareness of retail clients and the issues they face.

As a Chartered Financial Planner, Lorraine was also one of the first two people in the country to have fully completed the CII Regulated Diploma. Lorraine has extensive training experience at Regulated Diploma level, across all subjects, and is an Accredited CII Trainer.

Who is this course for?

This course is crucial for all members of staff affected by the SMF Conduct Rules.

'Extremely well presented and informative course. Very relevant and 'on target'.'

Managing Director

Alternative Investment Firm

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Sessions are practical workshops not PowerPoint lectures. All courses are limited to no more than 14 attendees, so we’re able to explain concepts in the context of your business.

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