28 posts categorised "Senior managers regime"

15 November 2019

Turning the SM&CR into an opportunity for solo regulated firms

By Grant Lee and Ann-Marie Stone In less than a month’s time, on 9 December 2019, the Senior Managers & Certification Regime (SM&CR) comes into effect for all remaining financial services firms. This completes the process following the banks and insurers which are already in the regime. How ready are...

22 October 2019

When an anniversary is actually a deadline: insurers’ final transition to SM&CR

While 10 December 2019 marks the first anniversary of the SM&CR for insurers, it is easy to forget that it is also a deadline. As the senior manager element beds down, one year on insurers must also have concluded the assessment process for Certified Persons, and provided training in the conduct rules to all remaining staff.

05 September 2019

Insurers and the SM&CR: Lessons from the banking stocktake report

As the December deadline approaches for insurers to finish certification under SM&CR, the FCA’s stocktake report on how banks have embedded the regime gives insurers the opportunity to learn from its conclusions. Any issues identified by the FCA in the banks will read across to other sectors.

25 June 2019

Senior Managers and Certification Regime – accountability and opportunity

It came as no surprise to anyone that once again governance and culture featured prominently as a cross sector priority in the Financial Conduct Authority’s (FCA) 2019/20 business plan. A key hammer to crack this particular nut will be the extension of the Senior Managers and Certification Regime (SMCR), which currently covers banks and insurers but will capture all regulated firms from the fixed implementation deadline of 9 December 2019.  But firms should not consider this in isolation, or as a ‘one off’ exercise - the governance and culture agenda continues to be an ongoing, permanent fixture of FCA supervisory focus and will likely be fertile ground for enforcement cases if current trends continue.

04 April 2018

What’s next for the FCA’s culture agenda?

By Sarah Isted and Tessa Norman The Financial Conduct Authority’s (FCA) recent discussion paper on culture is the regulator’s first tangible output on the topic for some time. With the Senior Managers & Certification Regime (SM&CR) due to be extended to all firms next year, now feels like the right...

15 March 2018

Preparing for SM&CR: the road ahead for consumer credit firms and insurance brokers

By John Coley and Sarah Nield Following the FCA’s December technical paper on extending the Senior Managers & Certification Regime (SM&CR), firms may have hit the pause button on their implementation plans. In the paper, the Financial Conduct Authority (FCA) announced plans to delay implementation of the extended regime from...

20 December 2017

When one SM&CR delay can lead to another

By Grant Lee The Financial Conduct Authority (FCA) and Prudential Regulation Authority’s (PRA) long-awaited technical consultations, to put more flesh on the bones of July’s broad policy proposals to extend the Senior Managers and Certification Regimes (SM&CR) to all FCA firms, arrived on 13 December 2017. Firms have been waiting...

20 November 2017

Senior Managers Regime: Reasonable steps - testing the outcomes

By Grant Lee and Andrew Strange A key tenet of the Senior Managers Regime (SMR) is the duty of responsibility placed on Senior Managers (SM). This is the new duty to ensure that as an SM, you have taken reasonable steps to discharge your responsibilities. On one level this doesn’t...

25 October 2017

What will the SM&CR mean for consumer credit firms?

Senior Managers & Certification Regime (SM&CR)

24 October 2017

Grandfathering into the Senior Managers Regime – more than just a technical exercise

By Grant Lee and Andrew Strange Most firms I speak to have now broadly absorbed the proposals in the Financial Conduct Authority’s (FCA) consultation on extending the Senior Managers Regime (SMR) to all firms, published in July. The more astute, however, are beginning to think about the upcoming technical consultation,...

13 September 2017

Client Asset oversight … when one becomes two

By James Steele-Perkins and Rob Anderson The Financial Conduct Authority (FCA) recently consulted to extend the Senior Managers and Certification Regime (SM&CR) to all sole FCA regulated firms. While wide ranging in scope, there are some particularly interesting Client Asset (CASS) requirements which firms need to consider, subject to the...

06 September 2017

Learning the lessons from the Senior Managers Regime

By Sarah Isted Over recent weeks, I've been asked by a range of clients and colleagues about the lessons learned from the introduction of the Senior Managers Regime (SMR) in the UK. These questions have been driven by two developments. Firstly, in the UK, the Financial Conduct Authority (FCA) is...

10 August 2017

Joining the dots in asset management: SMR and the market study

The Financial Conduct Authority’s (FCA) Asset Management Market Study and the extension of the Senior Managers Regime (SMR) to all FCA regulated firms - while both topics are separately initiated, increasingly the interlinkages make considering either in isolation challenging for firms.

03 August 2017

Senior Managers and Certification Regime: Be prepared

The proposals to extend the Senior Managers and Certification Regime (SM&CR) to all firms regulated by the Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA), will affect around 50,000 firms. Business preparations should start now.

19 April 2017

What can we learn from the FCA’s business plan?

Sarah Isted The Financial Conduct Authority (FCA) has set out its priorities and agenda for 2017/18 in its annual business plan. The regulator continues a number of themes from its work in 2016/17, while signalling an increasing focus on vulnerable customers, cyber resilience and FinTech. The FCA sets out six...

04 April 2017

The impact of the Chief Data Officer being brought into the Senior Managers Regime

By Nick.Bouch and Sarah Isted At the first anniversary of the Senior Managers Regime (SMR), many firms are reflecting on their population of Senior Managers. Some are particularly looking at whether the Chief Data Officer (CDO) or equivalent should join this group of individuals. Data management has gained significant attention...

01 February 2017

Financial Services Mis-selling: Minimising Risk

If we are to restore the integrity of the global financial services sector steps need to be taken by firms to minimise the risk of mis-selling.

FCA Asset Management Market Study: Governance to drive value?

By Amanda Rowland and Caroline Berryman While we believe that asset managers act as a ‘good agent’, mitigating conflicts of interests and contributing to better outcomes for investors, the interim results of the Financial Conduct Authority’s (FCA) asset management market study may tell a different story for some. The main...

08 September 2016

Six months in - what has changed with the introduction of the Senior Managers Regime

The Senior Managers Regime has now been live for six months. Has it made a significant difference to the way in which people are working or how the Regulators are supervising? It is perhaps too early to have a definitive answer to those questions, but it is clear from talking to senior managers that it is changing the way in which they think about their responsibilities and the reasonableness of their day to day actions. The question many will now be asking is 'will my preparations continue to be sufficient?'

09 May 2016

Culture and the Senior Managers Regime - a virtuous circle?

A review of the FCA's focus on culture in its recently published business plan and the role of the Senior Managers Regime in helping banks explore governance, accountability and drive cultural change.