Training Requirements for SM&CR

Okay, so let's move on and have a look at the specific training requirements, if we can just move to the next slide there. So, we've got here an extract. It's quite small there on the screen, but I've sort of highlighted the key areas there. An extract from C-Con, from the FCA handbook, which talks about the training requirements around the regime and the new conduct rules. So, we've got at the top there, if we can just work through the boxes. First, staff need to be notified of the new regime. They need to understand their responsibilities under it, and the firm must undertake suitable training. In terms of suitable training, we're looking at an awareness and a broad understanding of the conduct rules, but also a deeper understanding of the practical application in specific roles, particularly those in market facing and client facing roles, so particularly under rule four and five that you can see there on the screen. 

This was one of the areas that caused a lot of anxiety when this was first implemented in the first roll out of the regime because there was a lack of clarity around how detailed that role specific training had to be, and very little guidance, in fact, by the regulators as to how far that role specific training had to go. Firms really should make their own decision on that, as to how role specific they want, for example, scenarios to be in the training. I think in terms of guidance, I think the direction of travel when the banks and other firms who were caught by the regime in the first roll out, the second roll out of the training, perhaps stepping back from the very, very detailed role specific scenarios, et cetera, that we use first time around, and more of a reliance on other training that goes on within the firm to satisfy that requirement in terms of the role specific understanding of the application of the conduct rules.