Okay, it's a couple of minutes past the hour, so hello everyone, and welcome to today's webinar hosted by me, Stephen Taylor, Chief Commercial Officer at MyComplianceOffice. And Liz Hornby, Principal Learning Consultant at Eukleia. Today's webinar is titled The Senior Managers and Certification Regime: Five Lessons Learned from the Banking Sector

Okay, if we move on to lesson four now, and we think about infrastructure ... Now, I mentioned right at the beginning that there is a lot of infrastructure to put in place around the regime, and that's one of the reasons for having a long lead time to make sure that you've given yourself enough time to put this in place. As well as the infrastructure, you also need to make sure that all of this is fully documented and fully maintained, kept up to date. That brings us back to that term, reasonable steps, that we looked at earlier. It's important throughout this regime that you have the documentation to be able to evidence that you are complying with the regime, and to be able to evidence that you've taken reasonable steps. So perhaps more bureaucracy, more file keeping, making sure on a regular basis that everything is up to date, and to test yourself, perhaps, regularly to think what if the FCA were to turn up now and unexpectedly, you know, are we in good shape, and to make sure that that's part of your monitoring process.

Also, the annual certification process itself involves quite a lot of infrastructure. You will have to assess that people are fit and proper on an annual basis, so that will involve doing annual checks. You will also need to make sure that you have manager training in place as part of that fit and proper sign off. Both tailored training and general training, and that will include training beyond the individual conduct rules. Role specific training will be required across the firm. We've also got recruitment processes and appraisal processes that will be touched as well. So, without going into that in a lot of detail, I think you can see from the slide there that there is a lot of infrastructure that needs to be put in place to support the different strands of the regime as it's implemented.