The FCA has published an update on the timescales and delays currently being experienced by firms that submit application for approval. The update is shown below.
“We communicated in December 2020 about the delays in determining SMR (Senior Manager Regime) and SIF (Significant Influence Function) applications, following the large volume of applications received before the extension of the Senior Managers and Certification Regime (SM&CR).
We increased resourcing to address the delays and made good progress in determining most applications which had breached their statutory deadline and reducing the allocation times for applications.
However, in Q1 2021 we received significantly higher volumes of applications than we forecast. As capacity was down due to Covid-19, we were not able to bring our case volumes and allocation times back to business-as-usual levels by the end of the financial year as planned. Therefore, we’re sorry that applicants may still face delays while we increase resources.
Applications to hold a Controlled Function at an Appointed Representative that are both routine and non-routine are dealt with by the same teams as handle Senior Manager applications. Because information about such candidates will be examined in detail, these also take longer to determine. You can help us to process your application as quickly as possible by:
- carefully checking the application before submission to ensure that it has been completed in full
- remembering that for SMR applications you must complete a Disclosure & Barring Service (DBS) check before submission
- making sure you have conducted, and included, all appropriate due diligence checks, including regulatory references, before submitting a candidate
- responding promptly and fully if we contact you to seek further information about a submitted application”



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 […]