SMCR superseded the Approved Persons Regime on 9 December 2019. At a high level, firms need to:
Identify employees undertaking Certification Functions, which includes those employees who interact with clients, are material risk takers, are proprietary or algorithmic traders or who perform a significant management or supervisory role
Introduce new Conduct Rules, which are similar to the previous FCA Statements of Principle for Approved Persons, that apply directly to most (if not all) employees within a firm
Ensure timely reporting to the FCA for Senior Manager appointments and any conduct rule breaches by employees
Ensure accurate and timely information is posted on the new FCA Directory
Implement a formal fitness and proprietary assessment that requires a number of due diligence checks on an initial and ongoing basis for both Senior Managers and Certified Function holders
Implement a suite of new written policies and procedures that document a significant number of new requirements that SMCR brings into play
Identify Senior Managers who are personally responsible for the areas of business that they manage
Develop and apply a more formal training programme
What you are required to do under the SMCR depends on whether your firm is classified as Limited Scope, Core or Enhanced. If you are unsure what category your firm is please contact us or use our helpful diagram from the FCA below.
Click on your type of firm below, to learn more about our complete range of services which will ensure that you are SMCR compliant.