If you are a solo regulated FCA firm currently working on the SMCR Project - think about building in conduct risk measures now. Start with WHY. What led to the SMCR Regime? Look at public opinion post-2008...
Start with these questions now:
1. Has the Firm clearly articulated its conduct risk: definition appetite; taxonomy; desired outcomes; measures; testing; tolerances; and, strategy?
2. How does the firm conduct risk framework align to its business model, customer base, product offerings and jurisdictional footprint?
3. How does the conduct risk taxonomy take into account behavioural economics biases for senior managers, employees and customers?
4. How does the firm identify new/changing conduct risks e.g. from upstream risk, read across, people/structure geographical presence/, systems/product change etc.?
5. What remediation has the firm put in place to address already identified conduct risks, and what Management Information (“MI”) does the firm have to assess effectiveness?
If you need help with your conduct risk programme then please email me on Tyler.firstname.lastname@example.org