How to Prepare a Credible SM&CR Statement of Responsibilities Update After a Senior Hire

A new Senior Manager hire is the moment your governance map gets tested. The Statement of Responsibilities (SoR) you file, along with the updated Management Responsibilities Map (MRM), is the FCA's primary evidence that accountability is allocated clearly and that no Prescribed Responsibility has been dropped, duplicated, or fudged in the handover. Rushed or copy-pasted SoRs are one of the most common weaknesses supervisors flag, and they are entirely avoidable.

Key Executive Takeaways

• The SoR must describe what the individual is actually accountable for in plain language, not restate the FCA rulebook or their job description.
• Every Prescribed Responsibility must have a clean chain of custody: who held it before, when it transferred, and who holds it now, with no gaps or overlaps.
• The SoR, MRM, Form A or J, and handover note must tell one consistent story; inconsistencies between them are what trigger supervisory questions.

Start with the accountability, not the document

Before anyone opens a template, get the incoming Senior Manager, the outgoing incumbent (if there is one), the Chair or line manager, and the SM&CR lead in a room. Agree what the role is actually accountable for, which Prescribed Responsibilities move, which shared responsibilities need re-allocating, and which business divisions or legal entities fall inside the remit. This conversation is the substance of the SoR. If you cannot answer these questions verbally with precision, you are not ready to draft.

Sequence the drafting properly

Work in this order:

1. Update the MRM first. The map shows how responsibilities sit across the firm. If the map is wrong or stale, every SoR built off it inherits the error.
2. Draft the new SoR against the updated map. Cross-check that each Prescribed Responsibility on the map has exactly one owner (unless legitimately shared and documented as such).
3. Update the outgoing incumbent's SoR to reflect what they no longer hold, with effective dates.
4. Update any adjacent SoRs affected by the reshuffle. A senior hire rarely touches only one document.
5. Reconcile against Form A (for external hires) or Form J (for internal changes) so dates, scope, and role descriptions align exactly.

Write it so a supervisor can understand it cold

The FCA reads SoRs without your organisational context. Use short, specific sentences. Name the businesses, legal entities, product lines, or functions in scope. Avoid internal jargon, acronyms, and matrix-speak. If the role has geographic or entity boundaries, state them. If certain activities are explicitly excluded from the remit, say so, this is often more useful than listing what is included.

What good looks like: a reader can identify, within sixty seconds, exactly what this person is on the hook for and what they are not.

Handle the handover evidence

For any Prescribed Responsibility transferring, produce a dated handover note signed by both parties covering: the state of the responsibility at transfer, known issues or open regulatory matters, ongoing remediation, and any material risks. This is not a bureaucratic nicety. If something goes wrong six months later, the handover note is what determines who was accountable and when. Store it with the SoR, not in a personal inbox.

Common failures to avoid

• Treating the SoR as an HR document. It is a regulatory attestation.
• Leaving Prescribed Responsibilities temporarily "with the CEO" as a parking space. Regulators notice, and it usually indicates the reallocation was not thought through.
• Copying the previous incumbent's SoR verbatim. Roles evolve, and the new hire may bring different scope.
• Filing the SoR before the MRM catches up. The inconsistency is visible to supervisors.
• Vague language such as "oversight of" or "involvement in" without saying what decisions the person actually owns.

Board and committee alignment

The Nomination Committee or Board should see the final SoR before submission, particularly for SMF1, SMF7, and Chair roles. Minute the approval. If the hire changes committee memberships or chairmanships, update the terms of reference in the same cycle. Misalignment between SoRs and committee ToRs is a frequent finding in skilled person reviews.

Your next action

Before your next senior hire completes, book a ninety-minute accountability mapping session with the incoming individual, the outgoing incumbent, and your SM&CR lead. If that meeting cannot happen, the SoR is not ready to file, regardless of what the deadline says.

Frequently Asked Questions

When does the updated SoR need to be submitted?

For new SMF approvals, the SoR is submitted with the Form A. For changes to an existing Senior Manager's responsibilities, it must be submitted as soon as there is a significant change. Do not batch changes to save effort; each significant change is its own notification.

How do we handle interim or acting Senior Managers?

The 12-week rule allows temporary cover without SMF approval, but you still need to document who is holding the responsibilities and update the MRM. If cover is likely to extend beyond 12 weeks, start the approval process immediately.

Should Prescribed Responsibilities ever be shared?

Sharing is permitted but should be the exception and clearly justified. If you share, both SoRs must describe the split with precision. Supervisors are sceptical of shared PRs that read identically on both documents, that is a signal no one actually owns it.

What if the new hire's role does not map cleanly to existing responsibilities?

This is a signal to revisit the MRM as a whole, not to force the role into an ill-fitting slot. A senior hire is often the right moment to correct accumulated drift in the responsibilities map.

How much detail is too much?

The SoR should be comprehensive but readable, typically two to four pages. If it runs longer, you are probably including operational detail that belongs in a job description. If it runs shorter, you are probably being too abstract.