Why the First 90 Days Matter

Under the Senior Managers and Certification Regime, a Senior Manager’s accountability begins when they start performing the function. If a breach occurs in their area in their first month, the regulator will ask what they knew and what they did, just as it would a year later. A new Senior Manager can’t be expected to fix everything at once, but they can be expected to understand their area quickly, identify the main risks and act on them in a sensible order.

The first 90 days also set the tone. Colleagues, the board and the firm’s supervisors form an early view of a new Senior Manager, and it’s much easier to establish good habits at the start than to change them later.

Before Day One

Preparation starts before the first day. By the time of the offer, a new Senior Manager should have seen their draft Statement of Responsibilities and asked about the firm’s regulatory history. Before starting, it helps to request:

• the final Statement of Responsibilities and, for Enhanced firms, the Responsibilities Map
• recent board and committee papers relevant to their area
• any correspondence with the regulator about their area
• the handover document from their predecessor, if there is one
• the latest internal audit, compliance monitoring and risk reports covering their area.

Days 1 to 30: Understand What You’ve Inherited

Complete the Handover

If the predecessor is still available, spend time with them. Ask about open issues, known weaknesses, relationships with the regulator and anything they’d do differently. If there’s no handover, or it’s thin, record that fact.

Record the Starting Position

Write a short note of the state of your area as you find it: open issues, overdue actions, remediation in progress and gaps you’ve spotted. This protects you from being held responsible for problems that pre-date you, and gives a baseline against which your own progress can be judged.

Meet the People

Meet your direct reports, peers among the Senior Managers, the chair, the relevant committee chairs, and the heads of compliance, risk and internal audit. Ask each of them the same question: what worries you about my area?

Review the Management Information

Look at what information you’ll receive about your area, and whether it tells you what you need to know. If it doesn’t, ask for better. The request itself is worth recording.

Understand Delegation

Map who does what in your area and what you’ve inherited by way of delegated authority. Under the Senior Manager Conduct Rules, you remain responsible for overseeing anything you delegate.

Days 31 to 60: Prioritise and Act

Agree Your Priorities

By now, you should have a view of the main risks in your area. Agree the most important priorities with your chief executive or chair, and record them. It’s reasonable not to fix everything in the first two months. It’s not reasonable to ignore a serious risk you’ve identified.

Escalate What Needs Escalating

If you find something serious, such as a breach, a significant control failure or a matter the regulator may need to know about, escalate it promptly and record that you did. Waiting until you’ve fully understood the problem can look, in hindsight, like inaction.

Check Your Statement of Responsibilities

With a better understanding of the role, check whether your Statement of Responsibilities accurately reflects what you’re doing. If it doesn’t, raise it now. It’s far easier to correct at the start than after something has gone wrong.

Establish Your Governance

Set up the regular meetings, reporting and oversight routines you’ll use to manage your area. These routines become the evidence of reasonable steps.

Days 61 to 90: Embed and Report

Report to the Board

Towards the end of the first 90 days, give the board or the relevant committee a short report on your area: what you found, what you’ve done, your priorities and any support you need. This formalises your starting position and gives the board a clear view.

Meet the Supervisor

For significant roles, it’s often worth meeting the firm’s supervisors early, usually alongside the chief executive or compliance. Supervisors appreciate hearing directly from new Senior Managers about their priorities.

Review Delegation and Resources

Confirm that the people you delegate to are capable, that you receive what you need from them, and that your area has the resources to meet its obligations. If it doesn’t, make the case, and record it.

Plan the Next Phase

Set out your plan for the rest of the year, including remediation, improvements to controls and any structural changes.

For Control Function Holders

New compliance officers, MLROs and chief risk officers face particular pressures. They often inherit monitoring plans, regulatory reports and investigations already under way, and their independence depends on establishing direct access to the board early. For MLROs, reviewing the suspicious activity reporting process and the most recent MLRO report is usually a first-week priority. SMF Capital’s guide to SMF16 and SMF17 covers what the regulator expects of these roles.

For Firms Appointing a Senior Manager

Firms can make the first 90 days far more effective. A good induction should include:

• a proper handover, planned before the predecessor leaves
• access to board papers, regulatory correspondence and assurance reports from day one
• introductions to the chair, committee chairs and control functions
• management information designed around the new Senior Manager’s responsibilities
• a scheduled report to the board at the end of the period.

Where the new Senior Manager is a first-time holder, the application to the regulator may have committed the firm to extra support, such as mentoring or training. The first 90 days are when those commitments need to be delivered.

Finance Leaders

New finance directors and CFOs in regulated firms face the same accountability, often with prudential reporting, capital, liquidity and client asset responsibilities alongside the finance function. Their first 90 days should include a review of regulatory returns, capital calculations and, where relevant, client money arrangements. FD Capital, a sister practice of SMF Capital, places finance directors and CFOs in regulated firms and sees how much a structured start helps.

A 90-Day Checklist

• Before day one: Statement of Responsibilities, board papers, regulatory correspondence and assurance reports.
• Days 1–30: handover, starting-position note, key meetings, management information review, delegation map.
• Days 31–60: agreed priorities, prompt escalation, Statement of Responsibilities check, governance routines.
• Days 61–90: board report, supervisor meeting where appropriate, resources review, forward plan.

The Bottom Line

The first 90 days shape a Senior Manager’s tenure and their position if anything goes wrong. A structured start, with a clear record of what was inherited, what was prioritised and what was done, protects the individual and strengthens the firm. For more on the approval process that comes before, see SMF Capital’s guides to the fit and proper test and how long an SMF appointment takes.