There is a lot to think about and plan for prior to 9 December 2019. The good news is that you do not need to start with a "blank sheet of paper". In all likelihood, your existing governance and compliance structures are a sound starting point to be adapted and tweaked as needed to ensure SMCR compliance.
Some key items that should be on your "to-do" list include:
- assessing which FCA defined category of firm your business falls into: Core, Enhanced, or Limited scope and EEA and non-EEA branches of overseas firms;
- identifying your population of Senior Managers, including what Senior Management Functions they will hold;
- for Core, Enhanced and Non-EEA branch firms, considering the allocation of prescribed responsibilities;
- working on Statements of Responsibilities for your prospective Senior Managers and drafting new and/or updating existing job descriptions;
- for Enhanced firms, starting to prepare your Management Responsibilities Map;
- considering what a formal and documented procedure for assessing the fitness and propriety of certification staff on at least an annual basis will look like and how it will be implemented in practice;
- start drafting a handover policy and procedure if you are an Enhanced firm;
- identifying your Certified Person population by reference to which of the nine Certification Functions each person will perform;
- creating and implementing a documented process for a "living" fitness and propriety assessment process and procedure including identifying relevant "F&P" criteria, given firms and now "mini-regulators" in this respect; and
- start scoping bespoke Code of Conduct awareness training for each category of Code of Conduct staff.
For more information please contact our SMCR team.