The Frameworks
Three tools.
Recallable under pressure.
The book turns 161 pages of regulation into three frameworks an SMF can deploy at 9pm on a Friday without a lawyer in the room.
01 · The TRACE Framework
Five steps. One mnemonic. Tap to expand.
Define non-financial misconduct clearly. Set the line between conduct that is regulatory and conduct that is not, in language your staff and the FCA both recognise.
02 · The Evidence Pyramid
What actually holds up in front of the regulator.
Apex
Board minutes & SMF attestations
Highest weight
Upper
Contemporaneous emails & Teams messages
Strong
Middle
HR case files & investigation reports
Material
Lower
Training records & policy acknowledgements
Supporting
Base
Witness recollection (no document)
Weakest
03 · The SMF Risk Matrix
Drag the sliders to classify an incident.
SeverityModerate
Role exposureManager
Risk band
4
Green — line management