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.



Abridged advice – how is it going so far?
Alistair MacDougall Compliance 2015, 2018, 2020, 2021, abridged, Drawdown, FCA, Pension, Pension Transfer, PI, transfer
Based on data and live visits to firms during the period from April 2015 to rule changes in 2018 and 2020, the FCA believed that far too high a proportion of clients were being recommended to transfer safeguarded benefits. This was predicated on the longstanding rule which stated: “… a firm should start by assuming […]