The Senior Managers and Certification Regime (SMCR)

The Senior Managers and Certification Regime (SMCR)

"to do list"

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.

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