SM&CR: A Practical Approach "Reasonable Steps"

Location The Shard, 32 London Bridge Street

London SE1 9SG

Calendar May 1, 2019

SM&CR: A Practical Approach 'Reasonable Steps'

Duff & Phelps and Trailight for a workshop exploring some of the practical challenges SM&CR will bring ahead of the commencement date of December 9th, 2019.

Register now.


  • 08:30 a.m. – Registration and Breakfast 
  • 09:00 a.m. – Welcome and Seminar 
  • 10:30 a.m. – End

All the time slots mentioned above are in GMT

In this session, we will consider what reasonable steps really means for senior managers, and the broader implications for firms and individuals. We will discuss how the banks approached reasonable steps, some of the pitfalls that should be avoided, and how the use of technology has evolved and can form a core part of a reasonable steps framework.

Topics will include:

  • FCA policy objectives
  • How to turn theory into practice – applying reasonable steps to different types of organization and roles
  • Dealing with different management styles – being too prescriptive may not always be the best approach
  • Practical considerations for the oversight of delegated activities
  • Oversight of activities outside the senior manager’s direct span of control – dependencies on other functions and outsourced service providers
  • Enforcement considerations – the reasonable steps defense


  • David McNair Scott, CEO, Trailight
  • Mark Turner, Managing Director, Duff & Phelps
  • Jane Stoakes, Director, Duff & Phelps
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