In March 2016, the first round of SMCR "went live" across UK banks, building societies, credit unions and PRA designated investment firms. The extension of SMCR to all FCA (only) authorised firms will be effective from 9 December 2019.
The SMCR creates a system of personal accountability, underpinned by clarity of personal responsibility among Senior Managers, by ensuring firms and their staff have a demonstrable understanding of who does what and applying conduct rules to almost all staff across firms, including front office, back office, support staff and administrators.
In replacing the existing Approved Persons Regime, the SMCR represents a fundamental change in the regulatory framework of the UK financial services sector. This shift in focus will impact all aspects of a firm's operations - from governance, compliance, HR, customer and client service, to compensation and benefits and the careers and reputations of financial services professionals and their firms.
Effective implementation and compliance with the SMCR extension is imperative from a compliance, employee relations and broader franchise risk management perspective.
For more information please contact our SMCR team.