Reasonable steps: what are they and how do you evidence them?
A Senior Manager must take reasonable steps to ensure her function is controlled effectively and in compliance with regulation.
As highlighted in a recent speech by Mark Steward (Director of Enforcement and Market Oversight): “implementing the [senior managers regime] has meant firms have built into their systems explicit reasonable steps to prevent non-compliance. This has required an assessment of what may make a particular control system or function more vulnerable to failure because it is in those places that the senior manager’s reasonable steps need to be particularly evident.”
In this post, we consider what reasonable steps should look like in practice and the key areas where we expect a Senior Manager’s “reasonable steps” to be particularly evident/ well documented.
Click through to learn more about the key questions Senior Managers should be asking themselves to help determine what good looks like.
How we can help?
Whether new to role or a seasoned Senior Manager, we can provide induction or refresher training on reasonable steps and what good looks like.
We can test a Senior Manager’s framework for compliance. We would draw on our experience advising numerous firms across the financial services industry and our work on enforcement matters involving Senior Managers.
We can let you know how you fare against your peers, and provide insights into what the regulators really care about when things go wrong.
