SRA strategic plan 2012

Introduction

The Solicitors Regulation Authority is the independent regulator of solicitors, the firms in which they operate and all those working within those firms. It regulates in the public interest. Its work is overseen by the SRA Board, which is made up of 17 members, of which nine are solicitors (including the Chair) and eight are lay members. The Board exercises much of its oversight through five committees and two groups.

The Strategic Plan for 2010 to 2013 set a clear programme of regulatory reform and organisational and cultural change.

This update summarises the SRA's progress in delivering that programme, and sets out how it has developed and adjusted the programme so as to ensure it remains relevant for its remaining period. This has been done in the context both of progress to date and in the context of changes in the external environment.

The programme of reform and progress to date

When we set the strategic plan for 2010/13 we committed to delivering a programme which would:

• fundamentally change our approach to regulation from rules based to principles based, outcomes focused and risk based;
• enable us to license alternative business structures (ABS); and
• radically reform the SRA as an organisation.

What we set out to deliver was—and still is—an ambitious programme of transformation, which encompassed intensive policy development, consultation with legal services providers, consumers and government, assessment and training of the entire SRA staff, an organisational overhaul and the replacement of legacy IT systems.

At the forefront of our achievements in 2011 was the successful launch of outcomes-focused regulation as well as the approval of our application to be a licensing authority for alternative business structures. Staff have demonstrated outstanding levels of commitment and resourcefulness in delivering significant change to tight timescales and in challenging individual circumstances. As an organisation, the SRA demonstrated the ability to deliver on time and to budget, emerging as a more effective organisation and a more modern regulator.

2012 will be a year of consolidation as we seek to embed the new ways of working brought about by the introduction of outcomes-focused regulation. It will also see the continuing implementation of the Transformation Programme as we deliver the final phase of the Enabling Programme and see the introduction of newly recruited staff into the organisation. One of the greatest transformational challenges for the coming year will be the management and delivery of the move to the single, central Birmingham site.

2012 will also be time to look forward to 2013—OFR and beyond—and to consider how the SRA can, through its competence and effectiveness, remain the principal regulator of legal services.

Our vision

We will be the leading regulator of legal services, protecting the public, empowering, supporting and developing our people, providing value for money, fair and transparent outcomes and service excellence in everything we do.

Our values

Our values are embedded across all aspects of our work—they provide the framework for how we will develop as an organisation.

Objectives for 2012

Taking into account our progress to date, and the changes in the external environment, we have revised our objectives for 2012.

Therefore our objectives for 2012 are:

• Objective one: continue to develop the SRA's regulatory arrangements to deliver more proportionate and better targeted outcomes-focused regulation in the public interest;
• Objective two: support high standards in the delivery of legal services through education and training and the operation of outcomes-focused, risk-based regulation;
• Objective three: continue our programme of organisational reform to support delivery of our current and future objectives.

Our key activities to meet these objectives are set out below.

Objective 1: continue to develop the SRA's regulatory arrangements to deliver more proportionate and better targeted outcomes-focused regulation in the public interest

An overview

The implementation of the SRA's new Handbook of regulatory arrangements on 6 October 2011 was a key stage in both the implementation of OFR and the achievement of ABS licensing authority status by the SRA. However, whilst the SRA considers it important that there is stability around these arrangements to enable those it regulates to implement and operate them, the Handbook will evolve.

Key activities in 2012 that will help deliver and achieve this objective include:

• playing a leading role in the debate on the scope of the regulation of legal services;
• ensuring that the needs of consumers and the consumer voice are properly considered in the development of the SRA's regulatory arrangements through engagement with consumer bodies, direct engagement with consumers and through a targeted programme of research;
• conducting major reviews, and implementing the outcomes, of the SRA's approach to regulating;
• conveyancing and the holding of client money; overseas practice in-house practice the effective management of legal practices, including assessing ongoing viability;.
• implementing the outcome of the financial protection review including amendments to the SRA's arrangements for compulsory PII and to the Compensation Fund;
• implementing the outcome of the government's planned changes to the regulation of referral fees;
• maintaining the timeliness of SDT prosecutions and improve adjudicator decision making;
• auditing our decisions to ensure fairness and transparency;
• developing performance measures to assess our impact in the key policy areas we target.

What will success look like?

• As the principal regulator of legal services, we contribute our knowledge and expertise to the review of the scope of the regulation of legal services;
• We develop a framework for capturing consumer opinion and experience, allowing us to reflect the consumer and public interest in our policy making and procedure development;
• We enhance our regulatory approach in areas posing the most substantial risk to clients or where there is fundamental change;
• We coordinate a cross-SRA approach to consumer protection that enables us to make the most of our contact with consumer representative bodies and where possible with consumers themselves;
• We provide the appropriate financial protection and compensation arrangements for consumers;
• Our monitoring and investigative activity is better targeted through the more effective use of intelligence and based on robust risk criteria, and our resources are focused on dealing with serious risk;
• Our responsive, proportionate and transparent regulatory decision making ensures consumers are appropriately protected;
• The most serious disciplinary allegations continue to be prosecuted before the Solicitors Disciplinary Tribunal, and we deal effectively with less serious matters using our own disciplinary powers;
• We transparently evaluate our policies to ensure they are effective in delivering the right outcomes; and the SRA is known for its fair and transparent decision making.

Objective 2: support high standards in the delivery of legal services through education and training and the operation of outcomes-focused, risk-based regulation

Overview

In 2010/11 the SRA restructured its operational delivery around its three core regulatory functions of authorisation, supervision and enforcement, all supported by a single central risk centre. In addition, during that period, the underpinning operational policies and processes for each of theses functions, and for the interactions between them, to deliver OFR and ABS licensing were developed.

The SRA moves into 2012/13 with these building blocks in place but recognises that significant management focus will be required in the coming period to ensure that these new structures and processes are operating effectively and efficiently to deliver OFR and ABS licensing in the public interest. This will include continuing review in order to identify what is working well and what is working less well and, therefore, requires adjustment. This review will include seeking and considering feedback from those we regulate, from consumers and from other stakeholders.

Key activities in 2012 that will help deliver and achieve this objective include:

• licensing alternative business structures;
• embedding new risk-based authorisation and supervisory arrangements for all firms;
• building on the success of our relationship management and supervision pilots, by piloting further approaches in thematic supervision;
• assuring the development of OFR and risk-based regulation through consistent processes and independent assessment;
• continuing to help the profession in making the transition to OFR by providing them with clear information, and using a variety of media, enabling us to reach the widest possible audience;
• implementing fully the new suitability test including the use enhanced risk-based vetting of individuals;
• embedding our new regulatory decision-making frameworks, developed to support OFR, across the SRA; completing the review of legal services education and training and implementation of the recommendations;
• maintaining and enhancing relationships with key media, professional, political and other stakeholders and developing close working relationships with the Legal Services Board, the Legal Ombudsman, the Law Society and other approved regulators to deliver excellence in legal services regulation;
• cementing our relationships with the Council for Mortgage Lenders (CML), Association of British Insurers (ABI), Financial Services Authority (FSA), and other relevant organisations to work together to combat fraud;
• developing our approach to regulation for international firms.

What will success look like?

• We operate independently assured risk-based, outcomes-focused authorisation and supervision for a regulated community which includes alternative business structures;
• We target our monitoring and investigative activity through the effective use of intelligence and based on robust risk criteria;
• We successfully communicate the changes brought about by OFR to the profession who understand and implement them throughout 2012;
• We manage down our pre-OFR workload to ensure a smooth transition for those we regulate and for our staff;
• The system of education and training for solicitors is risk based and developed on a sound evidence base to ensure fitness for purpose to meet the needs and expectations of consumers now and in the future and we continue the reform of education and training to deliver agreed outcomes of the qualification pathway and continuing professional development levels;
• Our approach enables high standards and flexibility for firms, both nationally and internationally.

Objective 3: continue our programme of organisational reform to support delivery of our current and future objectives

Overview

The transformation of the SRA's regulatory approach has been accompanied by a major internal programme of reform. During 2010/11 the SRA has made significant process in organisational restructuring, in reshaping its workforce (in terms of numbers, activities, knowledge, skills and behavioural competences) and in implementing new internal IT systems and externally facing online services.

Key activities in 2012 that will help deliver and achieve this objective include:

• implementing our new governance arrangements with the Law Society and ensuring we have the correct internal governance and committee structures in place;
• completing the implementation of the SRA's Enabling Programme (of changes to supporting IT systems and online services) and ensuring that the benefits have been realised;
• developing standards of service so all those who interact with us understand what to expect; and that they experience an organisation with professional, well informed staff;
• embedding our equality framework within our strategic and business planning;
• ensuring our internal, external and digital communications support our development;
• developing our strategic plan for 2013-2016, confirming our long term commitment to delivering high regulatory standards and supporting the development of the legal services in the public interest;
• developing our measurement and reporting tools to enable us to transparently report our organisational progress in terms of output and impact;
• improving our internal drivers for efficiency and developing our capacity to report transparently on the costs of regulation;
• completing our move to a single midlands site in central Birmingham;
• supporting staff in their roles through a package of measures including talent management and leadership programmes and the introduction of a matrix-style structure, bringing greater flexibility and opportunity into job roles; as well as ensuring our staff have been fully trained in the new ways of working;
• increasing the diversity of our workforce at all levels of the organisation, but particularly the senior levels.

What does this mean?

• Our organisation and staff are committed to the delivery of outcomes-focused, risk-based regulation and this is evident in our processes and ways of working;
• Our stakeholders and staff know and understand the our goals, the intended outputs of our work, the impact we intend to have year on year, and how we represent value for money in regulation;
• We attract and retain talented, motivated and well qualified staff who understand the businesses of those we regulate, are committed to delivering and developing regulatory best practice, and experience the organisation as "one" organisation;
• Our modern IT systems support the organisation to deliver excellent performance;
• We regulate and engage with the profession in a clear, transparent and accountable way, enhancing our reputation;
• We are synonymous with demonstrating fairness, consistency and prompt action in the public interest and our brand is increasingly known, both here and abroad;
• Our workforce is increasing in its diversity at all levels of the organisation.

These objectives and associated outcomes are how our success will be judged by both the organisation and our stakeholders. Details of how we will deliver these objectives, how will monitor progress and manage performance; the risks and challenges we face and the resources we need to deliver will be set out in the SRA Business Plan for 2012.

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