Taking Reasonable Steps - ZISHI

Taking Reasonable Steps

The aim of this 2 hour workshop is to unravel the confusion that lies around “reasonable steps” and shed light on the regulators expectations.

CPD:

2 CPD Hours

Reasonable Steps Flyer

Price per person (Ex. VAT): Provided on request

KEY BENEFITS

By attending this workshop you will be able to:

  • Gain awareness of the type of evidence the regulator expects to see
  • See examples of reasonable steps aligned to Prescribed and Other responsibilities
  • Understand when the requirement to take “extra notes” might arise
  • Clarify the need for evidence post leaving a senior management function role

COURSE OVERVIEW

The term Reasonable Steps is used in the first 3 SMF Conduct Rules:

  1. You must take reasonable steps to ensure that the business of the firm for which you are responsible is controlled effectively
  2. You must take reasonable steps to ensure that the business of the firm for which you are responsible complies with relevant requirements and standards of the regulatory system
  3. You must take reasonable steps to ensure that any delegation of your responsibilities is to an appropriate person and that you oversee the discharge of the delegate’s responsibility effectively.

But what does the regulator mean by the term ‘reasonable steps’?

 

The Culpability Standard states

“A person will only be in breach of any of the rules in COCON where they are personally culpable. Personal culpability arises where:

  • A person’s conduct was deliberate; or
  • The person’s standard of conduct was below that which would be reasonable in all circumstances”.

Do you or your Approved Persons (SMFs) understand what is expected of you in your execution of reasonable steps? 

 

The Course Agenda

Regulatory requirements

  • Clarify The Conduct Rules – A recap
  • Understand the relationship between Prescribed responsibilities, Statements of responsibility and Reasonable steps

 

Evidencing

  • Appreciate examples of reasonable steps documentation
  • Establish what counts as evidence

 

Access

  • Confirm when, what and how you may need access to evidence once you have vacated the role

If you have any questions about this course, please feel free to get in touch via email on info@thezishi.com or by calling 01908 395243.

The aim of this 2 hour workshop is to unravel the confusion that lies around “reasonable steps” and shed light on the regulators expectations.

CPD:

2 CPD Hours

Reasonable Steps Flyer

Price per person (Ex. VAT): Provided on request

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