Senior Managers & Certification Regime

Central to the regime is the ideal of putting customer interests first

and yet... there has been very little direct reference to customers in most of the coverage surrounding SM&CR. Strange considering the whole point of SM&CR is to add to the FCAs tool-set for driving cultural change away from reckless profiteering to one of genuine customer-centricity in the Financial Services industry.
Let IIC help you in your customer-centric approach to SM&CR.

In Focus: the FCA's customer-centricity drive

The FCA is enforcing customer-centricity because its associated behaviours, practices and principals provide a conduit for ensuring the necessary cultural shift to safeguard British tax payers from the fall-out of another financial crisis - one born out of profiteering and high risk decision making.

Since the 2008 financial crisis, regulators like the FCA have held many firms to account for failings, but very few individuals. The FCA directive for firms to "show consistently that fair treatment of customers is at the heart of their business model" didn't deliver the desired cultural change in the aftermath of 2008, and bad practice has endured.

SM&CR was introduced to address that failing, and its roll-out is continuing for solo-regulated firms on 9th December 2019 with a 12-month grace period thereafter.

In their own words, the FCA wants, "to improve standards of individual behaviour in financial services from the top-down and the bottom-up.” The conduct rules apply to almost all staff and, as a senior manager, you're on the hook for the actions of everyone below you. That includes ensuring they're all aware of the conduct rules and, more importantly, are following them.

Let's just remind ourselves of those conduct rules...

The key 5 "Individual Conduct Rules" of SM&CR

“These are a new set of enforceable rules that set basic standards of good personal conduct against which we can hold people to account” - The FCA

Customer-centricity is central to SM&CR, and is directly referenced as one of the five conduct rules.

4. You must pay due regard to the interests of customers and treat them fairly 

Preparation for 9th December

In the build-up to 9th December, solo-regulated firms should be well underway with preparations for SM&CR, and below are some of the considerations surrounding customer centricity that press home the need (or not) for a change in approach:

  1. If the FCA had a complete and honest view of our firm, would they think it was already fully customer-centric?

  2. If yes, is a box-ticking exercise to square-peg-round-hole our current operation all the preparation we need?

  3. Are we prepared to take that risk?

The reality is, many firms are putting a lot of work in to ensure compliance and to demonstrate accountability, while ostensibly missing the point about customer-centricity and the need to change approach.

Our message is, first of all don't get caught out, and secondly, get ahead of the curve by rooting your SM&CR preparation and ongoing approach in customer-centricity. It won't surprise you, but we can help you with that.

How can IIC help you with SM&CR compliance?

"a key feature of the SM&CR is to reinforce that firms need to take responsibility for their staff being fit and proper to do their jobs. This requirement also applies to Non-Executive Directors who are not Senior Managers, except in Limited Scope Firms. Once someone is in such a role, firms must assess them on an ongoing basis, and at least once a year."

What can we do specific to SM&CR?
Outsource annual customer auditing, segmented by department, team, individual.

What is the value-add with IIC?
We can help you deliver actual cultural change (which is the whole point of SM&CR)

An IIC assessment is a very sensible way for a business and its senior managers to evidence that customers' interests are central to their business and that all staff are following the conduct rules in this regard.

There is a risk that businesses will see SM&CR as a tick-box exercise and will be pre-occupied with all the peripheral requirements linked to certification. Whereas it is actually far more logical and future-proof to start with the treatment of customers - being the central driver to the desired cultural change the FCA are driving at with the whole regulation.

it so happens that IIC assessments focus on exactly that. And that is no coincidence - we know putting the customer first is great for business long-term because it is good for the customer.

Outsourcing the work - take the pain away
Save time, save internal resource
Independent - asking the right questions and independently verified
Benchmarking - is it consistent across the business. IIC segmentation analysis allow you to see if customers are being treated fairly across the business. Benchmark across the industry - are you good or bad?

You've done all the main stuff, created the RACI docs, done your due diligence. Now we're approaching the 9th December, it's time to consider...

IIC gives you the insight and evidence you need

An IIC assessment collects feedback from customers to enable independent validation of your customer principles, culture and delivery. It demonstrates you have an ongoing commitment to customer feedback and improvement, because the insights gathered will help you address weak spots and enhance strengths, year-on-year.

The employee and manager feedback in our assessments also gives you an audit of your teams’ customer experience performance. Giving you the evidence that you regularly measure and have documented feedback, whilst providing you with reassurance in the context of the potential SMCR demands in this area.

Since 2006 we’ve been helping businesses harness the power of insight to improve their customer experience. Using a unique methodology, we’ve worked with hundreds of businesses, large and small, to help them understand what is going on with their business and how it feels to be a customer. We send tailored questionnaires to the vital stakeholders inside and outside of the organisation – including senior managers, employees and customers - interpreting the findings to shape enhancements that make the business more customer centric and profitable.

Cultural change beyond SM&CR

​Published in the PIMFA Spring 2019 Journal:

"Holistic wealth management (looking at more than just the numbers, encompassing all aspects including emotional satisfaction) will emerge as a new kind of digitalised business model. Holistic wealth managers are expected to gain a market share of 30% by 2025." - 2018 EY Wealth Management Outlook Survey

If today's financial advisors and wealth managers are hoping to compete in that future, how are they supposed to understand their clients' emotional satisfaction? To see beyond the financial numbers and be able to anticipate their clients' changing needs and expectations, firms need a system for gathering that data and implementing the findings in a way that will deliver this kind of cultural shift.

This level of customer-centricity is the sort of thing the FCA has in mind when trying to enforce cultural change with SM&CR. But frankly it's no more than what firms should be doing already if they wish to remain competitive in to the future.

For example, as Millenials become the market, they will bring with them new expectations based on formative experiences (like the 2008 financial crisis and global warming) that demand transparency, choice, societal wellness and more. The possible touchpoints available to them to transact investment will be many and complex, and tollerance for communication overload will be low. So how do you strike the right balance and stay on top?

IIC can help you deliver cultural change


Useful Links:

The FCA's "Fair treatment of customers" directive:

Senior Managers and Certification Regime: solo-regulated firms:

The Senior Managers and Certification Regime: Guide for FCA solo-regulated firms:
See page 43 onwards

IIC's unique 16-point methodology

Our assessments are built around four principles of customer experience, which are divided into 16 themes. This allows us to pinpoint your issues and areas of opportunity to develop, which we can feedback to you in our detailed IIC assessment report findings.

Principle 1

Principle 2

Principle 3

Principle 4

Bespoke questions can be added to the questionnaire to explain the 'why' - as numbers mean a lot more with the detail. We work with you to design these specific additional questions to add to our standard measures – to get the information that explains your underlying scores and helps identify key components of the resulting action plan we will build for you.

The IIC Award

Proof that you are customer-centric

Reach our standard during assessment and we'll accredit you with an Investor in Customers award – bronze, silver or even the exceptional gold standard - to promote trust and reassurance in your brand and to help you prove that you meet your regulatory standards for customer experience excellence.

Our credentials and insights into the SIPP market

To date, IIC has undertaken assessments on behalf of six SIPP Operators – ranging in size from one of the largest platform based SIPP providers to several smaller providers operating between 3,000 and 5,000 SIPPs.

The overall assessment scores achieved by these businesses varied from 6.97 to 8.84 out of 10 – which resulted in a range of IIC Awards from Bronze to Gold.

However, customers on average scored these providers 15% lower than the senior managers in these organisations. A very significant difference, which reaffirms the fact that senior managers tend to rate the customer experience and service they provide much higher than their customers do. Closer analysis shows ‘Anticipating Needs’ to have the lowest customer theme score – and notably the largest differential between senior manager and customer scores – an alarming 24% gap!

A more positive insight is that ‘Treating Customers Fairly’ is scored highly by customers across these businesses. However, again senior managers on average scored their business 17% higher than customers in this area.

An IIC assessment can help you establish the reality in your business, and identity and fix the issues that cause these discrepancies.

Barnett Waddingham’s most recent IIC assessment for their SIPP & SSAS business secured them an IIC Silver Award. Commenting, Andy Leggett, Head of SIPP Business Development had this to say...

Proven rewards with IIC

Delivering consistently brilliant customer experience means customers won’t just stay longer, they may buy other products and services and will recommend you to their friends and colleagues. For SIPP businesses dealing with advisers, the IIC Award will provide all important quantitative evidence to advisers of the quality of service they can expect. Employees will also be happier and are more likely to be retained. Using IIC insights and recommendations, we have seen:


of clients improve their service and scores by their second assessment, and many report a double-digit increase in profits.


have seen improvements in their customers’ loyalty, reducing expensive acquisition costs and creating powerful advocates of their brand.


have used their IIC findings to build employee engagement. Research shows a direct correlation between motivated employees and happy customers.

Here's why our clients recommend us:

  • The credible excellence of the insights.
  • Ease and cost efficiency of the service.
  • Strategic business benefits.
  • The endorsement of the Investor in Customers Award.

8/10 of our clients repeat their assessments with IIC, and many have agreed to act as a reference for us. You can see some on our website here. Just let us know if you would like to be put in touch.


 of our clients recommend us.


say we make everything as straightforward as possible.


agree we provide good on-going service and support, helping ensure their IIC assessment delivers measurable results.