We thought it appropriate to remind firms that the SM&CR comes into effect on 9 December 2019 for FCA solo-regulated firms. ATEB has published several newsletter articles outlining the requirements – start here if you want read our most recent article.
If you have not yet started your preparations for SM&CR – or even if you have – you might find the ATEB SMCR Guide for firms useful. An accompanying toolkit comprising checklists and document templates is also available.
Firms should ensure that all preparatory work has been, or is being, undertaken. In particular, firms must ensure that awareness training on the Conduct Rules has been undertaken and can be evidenced by 9 December 2019. The training should cover the first and second tier rules with Senior Managers and the first tier rules with all Certification Staff.
Firms have until 9 December 2020 to roll out first tier training to all other staff.
ATEB have produced a training module to help firms deliver Conduct Rules training. This, and our guide and toolkit can be found within the members’ area of our website.
Conduct Rules Breaches – follow up
Huw Reynolds Compliance Conduct, FCA, Pension, Senior Manager, Update
We wrote recently about the Conduct Rules and, in particular, breaches and notifications . See here. This article is intended to clarify some of the grey around COCON breaches. All of the following is taken from Policy Statement PS 18-14. When is disciplinary action required? When and how a firm decides to undertake disciplinary action […]