Managing SM&CR on spreadsheets, what it is actually costing your network
A spreadsheet costs nothing to open, which is exactly why its real cost rarely gets counted. For a network, that cost shows up in four places: rules that change while the sheet stays the same, errors nobody can see, evidence that cannot be produced when the regulator asks, and hours that never appear on any invoice. None of it is dramatic on a given day. All of it surfaces at once when someone outside the firm asks to see the record. What a principal firm actually has to keep track of SM&CR sits with the principal firm, not with its appointed representatives, which means the network carries the accountability for what its ARs do under the agreement. In practice, that gives a network a set of recurring, date driven obligations. A named Senior Manager needs to be accountable for oversight of the ARs. Staff of the network itself who hold certification roles must be assessed as fit and proper and certified every year. The FCA must be notified at least 30 days before a new AR is a...