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Senior Managers Regime Case Study

A national Programme of work affecting all banks/building societies, credit unions and PRA designated investment firms

ea Change Group were tasked with providing an experienced interim to lead on a critical programme for a Major Building Society in the North of England (4000 employees) to replace the existing "Approved Persons Regime" and to deliver the new Senior Managers Regime ("Regulatory Framework for Individuals") - a regulatory regime to rebuild trust, improve standards and culture in the Financial Services industry. As Project Lead our interim had accountability for a project team of 7.

Project scope and work completed:

  • Defined an overarching strategy and regulatory framework for the client to align, complement and build on an existing culture of trust by increasing transparency in decision-making and making personal responsibilities clearer
  • Designed and implemented the required regulatory deliverables to support the new regime
  • Assessed the impacts of the new regime on policies processes and procedures and designed and implemented required amendments
  • Designed and implemented governance and organisational changes to align with the new regime
  • Developed and implemented a Communication and Stakeholder Engagement plan.
  • Designed training programmes and communication briefings and facilitated roll out for 4000 employees
  • Identified and implemented employment related changes (employment policies, procedures, contracts etc.)
  • Engagement of third parties to provide management consultancy service on key changes in regulation- supplier selection and management.
  • Designed and delivered key activities to test the design and operational effectiveness of the new regime and manage transition into BAU.
  • Supported recruitment and on-boarding of brand new BAU team to embed the new regime

Key challenges:

  • Managing cultural and behavioural impacts
  • Proceeding at pace without the final regulations in place
  • Successfully embedding and engaging the business in the new framework
  • Practical issues of enforcing certain aspects of the new regime
  • Meeting on-going BAU requirements (increased MI and documentation requirements with restricted automated systems and processes)


  • Governance and Responsibilities for the new regime identified and designed: a framework designed, documented and approved at the appropriate committee/s
  • Key regulatory deliverables designed, approved and submitted: Senior Managers' Statements of Responsibilities / Management Responsibilities Map submitted to regulators within prescribed timescales
  • BAU processes defined and documented, outlining required activities, dependencies and resources
  • Stakeholders fully engaged to understand the changes. Communication strategy and plan designed documented and implemented throughout the project at all levels
  • Training designed, developed and implemented

The project was completed successfully within the timescales that were stated at the outset and the ea team received many plaudits.