The Final Countdown to Senior Managers and Certificate Regime (SM&CR)

March is almost here and Spring is in the air. So probably the last thing you are thinking about is whether you and your firm are ready for the Senior Managers and Certification Regime?  

However, the deadline for full implementation is 31 March 2021, deferred from 9 December 2020, and only a matter of weeks away.

Submit now! 

You will need to have certified all relevant staff and delivered Conduct Rules training to all those who haven’t yet received it. Don’t delay and  wait until the deadline of 31 March. Acting now will ensure there is enough time to ask questions and make sure the data you submit is correct.  

You must submit your Directory Persons data, via Connect, by 31 March 2021 but the FCA recommends that, if you are able to do so, you should submit sooner. The FCA will incrementally display data as they receive it. 

It is also important that you don’t wait until 31 March to remove staff who are not fit and proper from certified roles. 

If you are unsure whether you or your firm are affected or what steps you need to take now, there is further detail on the FCA website, including a user guide for firms and a SM&CR podcast.

Important Note: ATEB news is intended to provide general information ONLY. The content, including any views expressed or guidance provided, does not replace the need to comply fully with FCA Rules and Guidance. Unless you have discussed news article content with ATEB, and specifically how it relates to your circumstances, then ATEB disclaims all liability and responsibility and actions arising from any reliance placed upon it. For the avoidance of doubt therefore, any reliance you place on such information without our consultation is at your own risk.

ATEB Compliance offers compliance and regulatory advice.

ATEB Suitability provides report writing software for the financial services market.

Our View

Time is running out. In addition to the guidance and materials available from the FCA, ATEB are also able to assist firms to implement the SM&CR, including Conduct Rules training.

Action Required By You

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About the Author

Mike is a Chartered Financial Planner and a Fellow. He has been an ATEB consultant for over 10 years but has worked in financial services for a great deal longer. He has a wide breadth of experience covering banking and lending, home finance, pensions, investments, consumer credit and general insurance.

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