Be SEAR ready in 2020
In anticipation of a Senior Executive Accountability Regime for Irish Financial Service Providers, here are 12 Steps that our clients can take to become SEAR Ready in 2020.
12 Steps to being SEAR ready - Housekeeping
1. Review Job Descriptions to ensure that they are up to date and reflective of the roles currently held by individuals.
2. Review Employment Contracts to ensure that everyone has signed one, and that the one that is signed the correct one for the current role and terms.
3. Capture the current Governance Structure and clearly set out who the Senior Executives are today.
4. Assess compliance with the existing Fitness & Probity Regime and Minimum Competency Code (if applicable). Can you demonstrate how the firm is complying with current requirements?
12 Steps to being SEAR ready - Planning
5. Appoint a Sponsor – someone within the firm who can keep a “watching brief” on the legislative process, communicate effectively with stakeholders in the organisation and prepare an action plan.
6. Prepare a Responsibilities Map and a Regulatory Obligations Register (individual roles and responsibilities will need to be mapped to a firms regulatory obligations in order to demonstrate who is responsible for what).
7. Assess the current Governance Structure – is it appropriate to the nature, scale and complexity of the firm and its regulatory obligations?
8. Address any Gaps identified in the fitness and probity review. It will be more difficult to implement the new requirements if the old ones have not been complied with.
12 Steps to being SEAR ready - Influencing
9. Assign Ownership for the implementation of the new requirements and clarify the role of the board in setting the tone of the organisation and establishing accountability.
10. Take every opportunity to Engage in the legislative process, even if the new requirements will not apply to your firm at the outset. It is important to have your firm’s voice heard as this important legislative change evolves.
11. Discuss the Concept of Accountability. Arrange training and insight sessions for the board and senior management. Develop a common understanding of what it means to be accountable in your business.
12. Discuss the potential Impact of the proposed regime on the firm’s strategy, its purpose and its culture. Consider the potential challenges and the potential advantages.