The Senior Managers and Certification Regime (SMCR) replaces the current Approved Persons Regime and will be implemented on 9 December 2019.

Most senior managers will already be FCA Approved Persons and are likely to continue to need FCA approval. Every senior manager will need to have a ‘Statement of Responsibilities’ that sets out the matters they are responsible and accountable for. Some senior managers will be given ‘prescribed responsibilities‘ defined by the FCA. Larger firms will need to send ‘Responsibilities Maps’ to the FCA explaining their governance arrangements.

Investment managers, advisers and traders will no longer be FCA approved. The Certification Regime will apply mainly, but not exclusively, to client facing or risk-taking roles. Firms will need to certify that employees are fit, proper and competent to perform their role, re-certify them each year and publish their names on a new FCA Directory.

A revised conduct standard that the FCA says will provide a meaningful change in the level of conduct expected from those working in the industry is to be introduced. “COCON” will be extended to a wider population of staff and firms need to train them on how the conduct rules apply.  Firms will notify the FCA when they take formal disciplinary action against a person for breaching COCON.

With the addition or material update of seven handbook chapters, it is understandable that, to anyone implementing SMCR, the task looks daunting. But by identifying the core themes into a structured framework of delivery requirements, SMCR looks both more familiar and manageable.

Read our latest article explaining why there’s still time to implement SMCR effectively for 9 December.

Ellis Wilson provides firms with a Smart, Measured and Commercial Response to SMCR.

We offer advice, assistance, training and straight-forward policy updates to help you meet the FCA’s December deadline.

For a summary of our service proposal click here.