SM&CR was designed to improve individual accountability in regulated firms by allocating clear senior manager responsibilities, certifying fitness for key roles and applying conduct standards across staff. Firms offering regulated investment services, including platforms that issue or distribute regulated securities, will typically name senior managers for functions such as operations, compliance and customer outcomes. These named responsibilities make it easier to see who is accountable for things like client money, valuation governance and product oversight.
Certification and ongoing fitness requirements mean that people in customer-facing and risk-sensitive roles must meet competency and conduct standards. The Conduct Rules apply broadly and give regulators a basis for action where poor behaviour or governance fails consumers. For investors in fractionalised real assets, a visible governance framework, published statement of responsibilities and clear reporting lines are indicators that a platform treats operational and conduct risks seriously.
SM&CR does not eliminate commercial or market risk, but it raises the bar for governance and supervision. When assessing platforms, retail investors can look for published responsibility maps, evidence of internal controls and audit trails, and transparent escalation routes — all of which are outcomes that SM&CR seeks to deliver in regulated firms.
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