Compliance is mechanics. Culture and ethics is being able to drive. FCA focussing on that through SMR.
“A tale of three cultures” - The FCA continues it’s focus on using SMR to drive cultural change, arguing that firms with a “good” purpose value diversity, curiosity and experimentation, listen to their people, and allow them to challenge the status quo. Firms with a compliance culture, hell bent on simply complying with the rules, are falling behind. The FCA is refining its view of what SMR is for in really interesting ways. It’s clearly not just about having good documentation. I would like to see a study on whether SMR is effective in driving the kinds of changes which the FCA is seeking, and if so, how. Meanwhile the challenge for Senior Managers is how to use SMR and other levers to identify weaknesses in firm culture and fix them.
