SMCR Academy from Simmons & Simmons ("Simmons") is an elearning solution for asset managers that have to train their employees for the Senior Managers & Certification Regime (SMCR). Firms regulated by the UK's Financial Conduct Authority (FCA) have to submit the employees that are properly trained to represent the firm in the FCA's Directory by 31 March 2021. SMCR Academy is a set of modules that covers the topics required for training under the SMCR.
SMCR Training Requirements
The FCA requires firms to certify that employees in certain roles are fit and proper to perform their roles at least once a year. The employees need to be properly trained when they are listed by their firms in the FCA's Directory. To understand which employees need to be listed in the Directory, see Simmons information note here.
The FCA has published guidance on indicators of an appropriate training program, which generally describe a preference for substance over form. Some of the principal points of the guidance are:
- The program should not be a "rubber stamp" exercise that is not interactive or does not lead to new issues to be addressed. The FCA expects to see some staff fail and new development plans undertaken.
- Responsibility for training can be delegated, but Senior Managers should be able to demonstrate that they have adequate oversight over "fit and proper" training.
- SMCR training should be a detailed process which is integrated into existing HR/performance management processes.
- Fit & proper panels, which include Senior Managers of the firm, should be convened to consider marginal cases.
The FCA's Conduct Rules set minimum standards of behavior for employees who carry out financial services activities, and form the core of employee training. The FCA has also provided guidance on how to train employees for compliance with the Conduct Rules, which include the following:
- Training should be interactive and use realistic scenarios (not just obvious ones), rather than computer-based training which is not tailored to the circumstances that may confront an employee,
- Training should be reinforced regularly and effectiveness assessed.
- Conduct Rules should be linked to "fit and proper" or performance assessments.
In its guidance, the FCA is asking that firms improve on their usual course of business in their SMCR training. The interactive nature and continuous improvement requested by the FCA are demanding standards, and indicate that those responsible for training should reach outside the firm to ensure improvement.
The SMCR Academy
SMCR Academy is a series of 11 e-learning modules to support the training of employees on their role-specific responsibilities in relation to SMCR compliance. The content has been developed by the regulatory lawyers at Simmons, and brings the experience of Simmons to a firm's SMCR training. The content has also been created with the FCA's guidance on appropriate training in mind.
The modules are listed and described on the SMCR Academy product page, and cover both general training under the FCA's Conduct Rules and role-specific responsibilities. The modules are 5-45 minutes in length and are easy to fit into an employee's busy day. SMCR Academy is a practical and effective way to improve a firm's SMCR training, and bring in regulatory experience from outside the firm to support the FCA's goal that asset managers continuously improve their SMCR training.
In our reviews of the products sold on PartnerVine, we typically compare the product to what's available on the market. In the case of SMCR Academy though, it is hard to find a comparable offer. SMCR Academy brings the experience of the regulatory lawyers at Simmons to a firm's SMCR training, which can't be replicated by e-learning offered without the support of a major law firm. Compared to a set of training courses organised by a law firm without the benefit of the e-learning pedagogy of SMCR Academy, SMCR Academy has the following relative advantages:
- Access online. SMCR Academy is available on PartnerVine for download. A firm needs to have its own learning management system (LMS) that is SCORM-compliant. With an LMS, SMCR Academy can be immediately delivered to a firm's employees. More importantly, the employees can do their training on their own time via desktop, tablet or mobile.
- Training from the regulatory lawyers at Simmons. The financial services regulatory team at Simmons is regularly listed among the top ten in the UK. The lawyers contributing to SMCR Academy are leading individuals in financial services regulation. The team is uniquely qualified to provide the realistic and interactive training recommended by the FCA.
- Quality e-learning delivered at scale. Providing SMCR Academy in an elearning format allows Simmons to deliver extraordinary value for SMCR training. It also allows Simmons to combine the experience of its regulatory team to provide a broader scope of training scenarios than would be possible if the training was delivered in person.
SMCR Academy works with any Learning Management System (LMS) that is SCORM compliant. As a practical matter, most asset management firms have their own LMSs, and, by following SCORM, SMCR Academy will work with most of them. With a SCORM-compliant LMS, SMCR Academy is easy to roll out to a firm's employees.
Circumstances of Use
SMCR Academy is training specifically for the FCA's Senior Managers & Certification Regime (SMCR). Financial services firms not regulated by the UK's FCA are outside the scope of this product.
About Simmons & Simmons
Simmons is an international law firm with a specialisation in asset management and investment funds. With more than half of its 1,500 lawyers worldwide based in its London headquarters, Simmons is a leading law firm for asset managers regulated by the Financial Conduct Authority in the UK. Its financial services regulatory team regularly advises a broad client base of asset managers and alternative asset managers, particularly hedge funds.
Simmons has a long tradition of delivering legal services with software. Since the launch of its navigator series of products in 2007, Simmons has been innovating in the non-traditional delivery of legal services and delivering a comprehensive range of legal products. For more information, see here.
Users need to have a SCORM-compliant Learning Management System (LMS) in place to be able to use SMCR Academy. There is no technical support included with the product.
Purchasers have to agree to Simmons' terms before purchasing the product. The counterparty for purchasers is Simmons & Simmons Solutions Ltd., the software subsidiary of Simmons & Simmons LLP. There are volume discounts available based on the number of employees that will be trained, which can be seen on the SMCR Academy product page.
For the SMCR Academy product page, click here.
For an article on the launch of Simmons with PartnerVine, go to Simmons & Simmons Launch.
For a description of what a Learning Management System is, go to What is a Learning Management System (LMS)?
For a definition of SCORM, go to What is SCORM?
For a user guide on how we set up SMCR Academy on an LMS, go to How we set up SMCR Academy on an LMS.
For information on Simmons, go here.