"to do list" There is a lot to think about and plan even now that SMCR is in operation. Some key items that should be on your "to-do" list include: preparing to make certification decisions on or before the 9 December 2020 preaparing to make submissions to the new directory by the 9 Decemeber 2020 For more information please contact our SMCR team. NOTE: in light of the COVID-19 pandemic the FCA is consulting on an extension to the 9 December 2020 deadline to 31 March 2021. This extension would apply to: (i) the application of the Code of Conduct (COCON) to staff who are neither Certified nor Senior Managers; (ii) the date by which COCON training must be concluded for Certified staff and other staff subject to COCON; (iii) the deadline for submission of information about Directory Persons to the Register; and (iv) the deadline for certifying Certified Staff as fit and proper. This consultation seems likely to result in the proposed extension taking effect. The FCA has urged firms where possible to seek to comply by 9 December 2020. Please contact us if you have any questions.