The Chelsea flower show has always been the herald of the summer social calendar – Henley, Ascot, Wimbledon and of course the cricket. But what else can we all be doing during the fast approaching summer months?
Working in Financial Services the annual headache remains – How do we record and evidence the competence of our individuals (assuming we can’t record attendance at the events mentioned above as CPD). This will become even more of an issue when, in 2018 all FSMA regulated firms will have to internally certificate individuals under the Senior Managers Regime. Our colleagues already caught by SMR are grappling with this now and must have their Certification Regime in place by March 2017, but what does a competent employee look like and how do you evidence it?
In the first instance and most commonly we look at CPD – training and education undertaken over a period. The quieter summer months should be a good time to look at this and find some useful, relevant and interesting events or activities to attend and complete.
But is CPD enough on its own? The answer these days is “NO” because I suspect most of you reading this would say “just because someone attends some training doesn’t necessarily mean they do their job any better”. We need to look at their KPI’s and key competencies.
You have to go back to job descriptions and role profiles – what do you need the individual to do? And that will depend on the role. Remember Certificated Persons in the new world is likely to be a wider circle of employees than are currently covered by Approved Persons. Therefore your Head of IT, HR and Head of Settlements will potentially be included as well as your Investment Analysts, Investment Managers and other “material risk takers”. Competence for each of these will be different.
Rather than focusing upon your individuals on attending an international conference on exchange traded commodities (or the like), go back to basics and consider how you will build the infrastructure to record, evidence and then certificate your employees;
- Do you have a T&C Scheme? If you do what adaptions need to be made to cover the wider reach of the Certification Regime?
- Are all your job descriptions up to date and do they clearly indicate for each employee what is expected of them?
- How will the supervisors (managers/team leaders) measure the activities and demonstration of competence?
- What MI will you collect on individuals?
- Where will you keep all the data if the regulator asks for it?
If you want to spend your summer usefully, why not use our T&C Healthcheck questionnaire and see how you measure up. With years of trusted experience in this area we are always ready to lend a hand. So contact us to discuss any issues that may arise from the T&C Healthcheck.
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