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Five key considerations for HR when building an SMCR compliance plan

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HR Managers should now be fully aware of the Senior Managers & Certification Regime (“SMCR”) that has replaced the Approved Persons regime for most financial sector firms regulated by the FCA/PRA. This regulation will make a significant impact on the UK financial services industry and indeed any organisation now offering finance under FCA regulation.

The SMCR is a regulatory framework covering the conduct and responsibility of key employees. It is an FCA/PRA regulation with two core focus deliverables:

1. To encourage a culture where staff at all levels take personal responsibility for their actions; and
2. To ensure companies and employees clearly understand and can demonstrate where principal responsibility lies.

The framework has been implemented in stages to replace the Approved Persons Regime and has been in effect for major banks since 2016 and insurance companies since December 2018. It has now been extended to include all FCA-regulated financial services companies as of December 9th 2019. As such, many companies are still in planning when it comes to SMCR compliance, and HR departments are looking for guidance on the vital elements that they should consider during the process.

Ensuring compliance with the SMCR must now be high on the HR agenda, especially now all FCA regulated companies, not just the finance and insurance sectors, are expected to comply.

 

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