When the Senior Managers and Certification Regime (SM&CR) became effective for solo regulated firms on 9 December 2019, the FCA automatically converted roles held under the former Approved Persons regime to new Senior Manager functions.
Since then the change of regime has resulted in a very large volume of applications for new approvals. In the final four months of 2019 the FCA received over 6,000 SMR (Senior Manager Regime) and SIF (Significant Influence Function) applications. This is more than they received in the previous eight months and as a result the average length of time to determine these applications has increased.
The FCA has increased resourcing to reduce the volume of SMR/SIF applications in progress and expects to see the overall volumes reduce over the remainder of financial year 2020/21. However, applications may still take longer to determine over the next few months.
Applications to hold a Controlled Function at an Appointed Representative that are non-routine are also taking longer to determine as they are dealt with by the same teams that handle Senior Manager applications. Also, firms submitting candidates who either have been, or intend to become, involved with the provision of advice on defined benefit pension transfers, for example, should also expect these applications to take longer to be determined.
Firms can help the FCA to determine applications more quickly by:
- Carefully checking the application before submission to ensure that it has been completed in full;
- For SMR applications, completing a Disclosure & Barring Service (DBS) check before submission;
- Conducting all appropriate due diligence checks, including regulatory references, before submitting a candidate and including details of those checks with your application;
- Responding promptly and fully if the FCA request further information about an application.
Routine applications to hold a Controlled Function at Appointed Representatives are being processed within the relevant service standards.