What Is A Senior Responsible Officer (SRO)?

Law firms authorised by the Solicitors Regulation Authority (SRA) must make several key appointments within their teams to ensure their firm is compliant across the board, from COLPs and COFAs to Money Laundering Reporting Officers. These roles are tasked with supporting or upholding the firm’s obligations in respect of regulation.

Away from the regulatory aspect, one of the most important positions in many firms that conduct residential conveyancing work, is that of the “Senior Reporting Officer” (SRO), who is a critical figure as required for the Law Society’s Conveyancing Quality Scheme (CQS). In this article, we shall assess the role of an SRO, informing you of key aspects for consideration when deciding who to appoint. 

What Does an SRO Do?

An SRO is an individual responsible for overseeing compliance with the CQS framework for all residential conveyancing activities. They are charged with making certain that their practice adheres to the CQS rules and Core Practice Management Standards and managing risks to maintain the quality of conveyancing services. They achieve this in several ways:

• Establishing a robust, tailored set of documented policies, controls, and procedures.
• Implementing and reviewing risk management strategies and protocols within the firm.
• Maintaining a suitable culture of compliance throughout the relevant departments.
• Interacting with the Accounts team to monitor financial compliance and issues.
• Conducting periodic audits and assessments, and reviewing file management practices.
• Writing reports to senior management regarding compliance status and recent audits.
• Participating in reviewing client verification protocols, such as Electronic Identity Verification (eID/V).
• Providing or overseeing appropriate training for colleagues involved in conveyancing, including refresher training when deemed necessary from audit findings.

As the SRO is essentially the driving force behind CQS compliance within your organisation, it is important that:

1. You appoint the SRO at the very beginning of the process of preparing for the CQS application.
2. They receive and have completed the necessary training before the formal application is submitted to the Law Society.

Having the SRO nominated, trained and signed off at the start of the process can make the rest of the CQS application and acceptance process significantly easier and less stressful for all.

SROs are expected to have an “open door” policy, working closely with several other key post-holders in the firm such as Compliance Officers for Legal Practice (COLPs), Money Laundering Reporting Officers (MLROs), and Money Laundering Compliance Officers (MLCOs). 

To become an SRO, the appointed individual must complete a mandatory assessment within 6 months of a practice being awarded an initial CQS accreditation (this assessment will be explained later). If a firm hires a new SRO, they must also complete the assessment within 6 months of their start date, demonstrating sufficient knowledge of the CQS scheme to be in the role. 

How Often Should the SRO’s Tasks Be Completed?

The typical tasks managed by the SRO come with varying levels of regularity. For example, measuring staff compliance is an ongoing task, whereas comprehensive risk assessments may be conducted annually. However, urgent compliance concerns or training gaps should be addressed as and when they arise. 

SROs tend to review and update the policies, controls, and procedures (PCPs) at least once a year, but they may be prompted to review this more frequently in the event of any major regulatory updates, internal audit findings, or client-related complaints.

Who Should Be Appointed?

There are several considerations a firm should make to determine a suitable candidate for the role. Ideally, the candidate should be:

• Suitably connected with the conveyancing team;
• Experienced in conveyancing; 
• Already compliant and conversant with the CQS Core Practice Management Standards (CPMS);
• Someone with adequate access to information, insight, and data;
• Familiar with the CQS, its requirements and its evidence points;
• Comfortable working and communicating with other senior post-holders;
• Someone with sufficient seniority to make key decisions and implement CQS-relevant controls. 

Once a suitable candidate has been selected, there are several forms to fill out as part of the accreditation process. Two of these are directed towards the SRO, and the additional forms are for other relevant members of the conveyancing team. The relevant forms for the SRO are:

• The CQS Application Form
• The New SRO or Head of Conveyancing Form

Can CQS Tasks Be Delegated by the SRO?

SROs may choose to delegate certain CQS tasks to others, whether to internal staff or external providers. The Scheme Rules do not prevent this, but the primary role of an SRO cannot be delegated or outsourced; the officers themselves remain responsible and accountable for any tasks delegated to others, following the Scheme Rules. For instance, if the preparation of a firm's CQS reaccreditation application is assigned to a fellow team member, the SRO must still review and approve it, maintaining full oversight and responsibility.

What Is the SRO Certification Exam?

As mentioned earlier, an SRO must complete a mandatory assessment which must be completed before an SRO accreditation application is submitted. This exam, which currently costs £75 + VAT, is designed to evaluate the SRO’s competency in the core CQS elements, including:

• The CQS Scheme Rules
• The CQS Client Service Charter
• The CQS CPMS
• The Law Society Conveyancing Protocol
• The Onsite Assessment Guidance Notes

The assessment is a 90-minute, multiple-choice test consisting of 20 questions which are selected from a question bank. SROs must achieve at least 70% to pass the test, although two attempts in total are allowed. In the event that the core CQS elements are updated, such as in 2022, the Law Society Accreditations department will notify SROs to retake the exam.

Prepare for an Accreditation With PDA Legal

Achieving CQS accreditation is vital for legal firms since it demonstrates their commitment to maintaining high standards of conveyancing practice, and improves credibility and trustworthiness in the eyes of consumers and lenders.

At PDA Legal, we understand the tasks that legal firms undertake when preparing for CQS accreditation, and above all, the importance of achieving a successful application. Our expert team provides guidance through our CQS consulting service, supporting your firm through the accreditation process. For more information on how we can help you, please contact our team today.

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