The FCA has published two new bite-size SM&CR podcasts. These will be useful for firms currently preparing for SM&CR.
- Certification and regulatory references: The purpose and scope, plus practical steps firms can take to prepare.
- Conduct rules: The five Conduct Rules will apply to everyone doing financial services work. The podcast explains the training requirements around them and offers practical tips for training staff.
The latest guidance and information on SM&CR can be found here. We would recommend that firms check this link regularly between now and 9 December 2019.
In particular, firms should note the deadline of 24 November for submitting Form O (Opt Up Notification – for Core and Limited Scope firms only) and Form K (Conversion Notification – for Core and Enhanced firms only) if these are applicable.



MiFID II – Aggregated costs disclosure
Alistair MacDougall Compliance 2017, 2018, 2019, MiFID, PI
This new requirement is posing some questions about how it can best be implemented. We think that firms should wait until the mechanisms in the market place are a little clearer.