Business: Human Resources
New or Existing Role-Replacement
- The purpose of this role is to support SMR related processes and controls.
- The Individual Accountability Regime (“IAR”), established by the UK PRA and FCA, consists of the Senior Managers Regime, the Certification Regime, and Conduct Rules.
- The following responsibilities prescribed under the regime pertain to the firm’s compliance with the regime itself:
- Responsibility for the firm's performance of its obligations under the senior management regime
- Responsibility for the firm's performance of its obligations under the employee certification regime
- Responsibility for compliance with the requirements of the regulatory system about the management responsibilities map
- Responsibility for the allocation of all prescribed responsibilities
- To ensure compliance with these requirements, HSBC has designed and implemented an operating model consisting of a suite of process changes, and new processes, across a range of global businesses and functions. Coordination of oversight is achieved through the IAR Management Office (“IAR MO”).
- The Head of SMCR is accountable for the effective operation of IAR related processes and controls focused variously on:
- the Senior Manager (top/’executive’ tier) Regime, which continues to support regulatory approvals and maintenance of required regulatory artefacts and standards; and
- the Certification Regime, which oversee the operational delivery of certification and Directory processes.
- The Head of SMR is responsible for:
- ensuring regulatory requirements are in place and accurate for the SMR population
- acting as a key point of contact for changes to the Senior Manager population and the SMR
- managing the team to resolve queries and issues
- escalating issues to the Head of SMCR
- The SMR Analyst will report to Head of SMR, who is responsible for executing SMR related processes and controls.
Impact on Business
- The SMR Analyst will:
- Manage, track and update HSBC’s records relating to regulatory applications, Statements of Responsibilities and the Management Responsibilities Map and prepare updates and MI in relation to these.
- Support IAR MO controls by, for example, undertaking sample & marker/checker checks.
- Provide administration support for regulatory applications.
- Support management with minute taking / setting up meetings /controlling papers / diary management.
- Produce accurate and concise MI for governance forums.
- Update internal procedure documents. Provide ad hoc support to the wider IAR team.
Customers / Stakeholders
- The SMR Analyst will engage with wide a range of stakeholders and operating model participants including:
- The teams of the Senior Manager Functions (SMF).
- Control and support function teams including Regulatory Compliance, HR, SFR, Operational Risk, Company Secretary and Legal.
Leadership & Teamwork
- Build professional relationships with colleagues within the IAR MO, RC, HR, Corporate Security, Operational Risk, Co-Sec, and the lines of business.
- Prepare materials for IAR related presentations for management.
- Handle process related queries.
- Facilitate continuous improvement through the identification, implementation & sharing of best practice.
Operational Effectiveness & Control
- The SMR Analyst will be expected to:
- Appropriately identify and assess operational risks.
- Ensure activities assigned are adequately controlled in line with IAR MO’s process and controls framework.
- Comply with HSBC’s internal control standards and policies.
- Job Dimension
- Accurately process a high volume of transactions to the required regulatory standard and timelines.
- Deal with a high volume of enquires from a broad range of stakeholders, for example related to process issues, control breaks and data quality.
- Job Context
- The IAR applied from 07 March 2016 to UK banks and will be extended in 2019 to apply to all UK regulated financial services entities.
- The Senior Managers Regime applies to a population of c.140 key senior executives, including a number of the most senior executives in HSBC Group.
- Certification Regime requirements applies to a population of c. 4,500 managers and individuals with the ability to inflict significant harm on the firm or its customers.
- Rules of Conduct applies to c. 65k FTE worldwide, the majority located in the UK.
- IAR MO activities relate to mandated requirements by the UK regulators and are therefore business-critical for any UK-domiciled bank or in order to provide banking services to UK customers.
- No direct control of financial spend or budget within this role.
- Major Challenges
- Fast paced environment subject to continual change
- High transaction volumes. All transactions are subject to strict regulatory timescales and quality standards.
- The jobholder will ensure the fair treatment of our customers is at the heart of everything we do, both personally and as an organisation.
- This will be achieved by consistently displaying the behaviours that form part of the HSBC Values and culture and adhering to HSBC risk policies and procedures, including notification and escalation of any concerns and taking required action in relation to points raised by audit and/or external regulators.
- The jobholder is responsible for managing and mitigating operational risks in their day to day operations. In executing these responsibilities, the Group has adopted risk management and internal control structure referred to as the ‘Three Lines of Defence’. The jobholder should ensure they understand their position within the Three Lines of Defence, and act accordingly in line with operational risk policy, escalating in a timely manner where they are unsure of actions required.
- Through the implementation the Global AML, Sanctions and ABC Policies, supporting Guidance, and Line of Business Procedures the jobholder will make informed decisions in accordance with the core principles of HSBC's Financial Crime Risk Appetite.
Observation of Internal Controls
- The jobholder will adhere to, and be able to demonstrate adherence to, internal controls and will implement the Group compliance policy by adhering to all relevant processes/procedures.
- The term ‘compliance’ embraces all relevant financial services laws, rules and codes with which the business has to comply. This will be achieved by adherence to all relevant procedures, keeping appropriate records and, where appropriate, by the timely implementation of internal and external audit points, including issues raised by external regulators.
- The following statement is only for roles with managerial or specific Compliance responsibilities
- The jobholder will implement measures to contain compliance risk across the business area. This will be achieved by liaising with Compliance department about business initiatives at the earliest opportunity. Also and when applicable, by ensuring adequate resources are in place and training is provided, fostering a compliance culture and optimising relations with regulators.