In January 2019, in CP 19/4 the FCA consulted on changes to optimise SMCR. Policy Statement 19/20 summarises the feedback the FCA received on the Consultation Paper and sets out the final rules. These rules are relevant to all SMCR firms.
In general, the FCA has implemented the proposed changes to the SMCR as consulted on, which include:
confirming that the Head of Legal function is excluded from the requirement to be approved as a Senior Manager
clarifying the requirements and scope of the Certification Regime
extending Senior Manager Conduct Rule 4 (SC4) to non-approved Executive Directors at Limited Scope firms