We have mentioned SM&CR several times in recent weeks. As the effective date of 9 December is rapidly approaching, we make no apologies for mentioning it again. The FCA has issued the following information.
SM&CR for solo-regulated firms: one/two months to go
The FCA is extending the Senior Managers and Certification Regime (SM&CR) to FCA solo-regulated firms on 9 December 2019. This extension affects almost every solo-regulated firm, from very small firms to some of the largest global firms. It will help to set a new standard of personal conduct for everyone in the industry and is a chance to embrace change for the better.
Firms need to comply with the requirements of SM&CR from 9 December 2019. All firms who are preparing will need to identify Certification staff and train Senior Managers and Certification staff on the Conduct Rules. What else firms will need to do depends on their SM&CR Category – Enhanced, Core or Limited Scope. Enhanced and some Core firms will need to submit a Form via Connect.
Web pages
Find out more on the FCA’s webpages, which include checklists for each category. The Guide for solo-regulated firms is also a useful summary of the FCA’s final rules and guidance on SM&CR – it gives an overview of how SM&CR works and how firms will be moved to the new regime.
Video
Together with business leaders from AXA PPP healthcare and Fidelity International, FCA Head of Conduct Specialists, David Blunt, outlines the effects of SM&CR and its benefits for firms.
Link to the video here. Download the video here.
Podcasts
We also have three short Inside FCA podcasts which provide a clear and concise overview of what firms need to do to prepare for SM&CR.
- SM&CR and culture – Jonathan Davidson
- Conduct rules – David Blunt
- Certification – David Blunt



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 […]