The Senior Managers and Certification Regime will undergo its final extension to all solo regulated* firms in December. We are working on a guide and other materials to assist firms.
Meantime, the FCA has published a video that you might find helpful.
The video can be accessed here.
* A solo regulated firm is a firm that is regulated only by the FCA (and not also by the PRA).
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Although SM&CR for solo regulated firms does not commence until December, firms will benefit from doing some preparation in the coming months. This video might be of interest.
We are working on some materials and tools that will help firms prepare for SM&CR. Watch this space.
For information.
A temporary solution if there are problems obtaining an LEI in time for any affected transactions from 3 January 2018.
There are some apparent anomalies in the rules. We have obtained ‘clarification’ from the FCA.
The FCA has clarified some aspects of how the recording rules will apply to firms that are not Article 3 Exempt.
How will changes to compliance governance affect your company?
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.