Managers and Certification Regime accountability is most effective when it is translated into operating practice. Statements of responsibility should connect clearly to committee terms of reference, management information, controls and escalation routes.

A useful review starts with the business model and the decisions that create the greatest conduct or prudential risk. It then tests whether the accountable Senior Manager has the information, challenge and authority needed to discharge their responsibilities — and whether deputies and hand-offs are understood.

Documentation matters, but it is not the whole answer. Firms should be able to show how responsibilities are embedded in governance forums, risk assessments, issue management and lessons learned. Gaps can be addressed through targeted design, training and evidence rather than a wholesale rewrite.

GRT helps firms refresh SM&CR accountability design and deliver regulatory change within existing teams.