The Duty of Responsibility: What does it mean in practice?
The Senior Managers and Certification Regime will apply to asset management firms from 9 December 2019. From this date, Senior Managers will need to comply with new Senior Manager Conduct Rules and a new statutory duty of responsibility, which require them to (among other things) take reasonable steps to (a) ensure their business is effectively controlled and complies with regulatory requirements, and (b) avoid regulatory breaches occurring or continuing.
This briefing will consider the duty of responsibility and the requirements of the Senior Manager Conduct Rules, consider their impact on Senior Manager liability and discuss how investment management firms and their Senior Managers can mitigate potential risks by building an effective framework for compliance with these obligations.
Join us to learn:
- Why reasonable steps matter in the context of the duty of responsibility and the Senior Manager Conduct Rules
- How they impact SM&CR documentation
- Examples of reasonable steps
- Practical tips for investment management firms and their Senior Managers in building an effective “reasonable steps framework”