Extension of the SMCR to all financial services firms
As we all know, the Treasury has directed the FCA to extend the Senior Managers & Certification Regime (SMCR) to all financial services firms in the UK.
Many firms have still not started to prepare for their SMCR deadline of 9th December 2019.
Jonathan Davidson, Executive Director of Supervision – Retail and Authorisations at the FCA, said:
“Senior leaders should view the regime as a catalyst to inspire positive culture change at their firms. The SM&CR is an important way to ensure that individuals at all levels within firms take personal responsibility for their actions. It is good for business when employees buy into a firm’s purpose, feel personal accountability and are inspired to speak up (and to listen). This can be encouraged through the new conduct rules. This kind of culture supports a healthy and inclusive workplace for employees, innovation and sustainability, and thoughtful identification and mitigation of risk.”
We have created a 90+ point project plan for all firms, Limited, Core or Enhanced where we can conduct the entire project for you or you can buy our plan and conduct it yourself. Be warned, that the SMCR implementation has been estimated to take over 32 working days to implement at each firm.
For any firm that wants to “Do-It-Yourself”
This document contains the overall project plan in 90+ points for most firms (Core & Enhanced with 82 for Limited) and covers 12 areas where your firm needs to review, assess and make changes.
Providing a complete working model for every firm is nigh on impossible but this project plan should fill 99% of firm’s needs for an effective SMCR regime and identify other areas that need addressing.
Although a Responsibilities Map is not required for Core Firms, we recommend you complete it. This has the benefit of a centrally stored record of the actions taken.
The last tab, entitled “Basic Information of Firm” is to consolidate all the information you may need for form, references and any other regulatory function required. It provides a ready use facility to clarify the elements of SMCR that apply to your firm, and a responsibilities checklist to make sure you are compliant.
We provide 6 pages of inter-related information including all the responsibilities and corresponding relevance to your type of firm. Using colour coding we identify the specific areas relevant to your requirements as well as a matrix to ensure you comply with the rules specific to your firm.
The 12 areas covered are;
- Map all SMF’s
- Complete SORs
- Undertake gap analysis of FCA requirements for Management Responsibilities Map
- Identify contractual changes for SMFs/NEDs (as appropriate)
- Job Descriptions & Fitness & Propriety Needs
- Processes & Procedures
- Outsourcing (or in-sourcing) of Key activities – Appropriate arrangements in place.
- Policy For Certificated Employees – Discussion with HR
- Management Information
- Identify employees for the Certification Regime
- Staff & Directors/Partners Onboarding
- Establish the training requirements (content, dates and venues) re the SMF’s, notified NED’s and Certified Employees re Conduct Rules
These are written across the 5 main areas;
- Training Requirements
For Only £2,995!
There are Twelve Main Elements for the project plan;
- These are covered in detail with deliverables for each, clearly labelled for the type of firm they are relevant to.
- Each of the 6 pages of the plan cover essential areas you need to review and confirm (screenshots below)
- The completed document forms the foundation of proving compliance with the new regime
This is the exact same plan we use for client firms to implement their SMCR preparations
– and you can use the same today!
What Do You Get For Your Money?
For Only £2,995!
If you require assistance in implementing your SMCR or anything in between a DIY or DFY, we can offer competitive rates.
Contact us for details of your package 0207 097 1434