Is the Senior Managers and Certification Regime Changing Banking for Good?

Abstract

In 2016 the Senior Managers and Certification Regime (SMCR) came into being. It sought to improve banking culture through the attribution of responsibility to individuals and to provide clarity on required conduct standards. It marked a shift away from collective responsibility and towards more individual accountability that had been so lacking following the financial crisis of 2007/08. Its scope is expansive, including not just board executives but also senior managers. In this paper, I question whether there are indications the SMCR is achieving its objective of ‘changing banking for good’. I do this by analysing the design of the SMCR and its application in practice as well as the meaning and regulatability of culture. I conclude that though the SMCR could make strides towards better banking culture, its potential is being curtailed by inconsistent messaging and irresolute application.