Making Compliance Work: The SM & CR For Solo Regulated Firms

smcr, senior managers regime

So it’s Finally Here – Solo Regulated Firms From the end of 2019 will be under the SM&CR regime.

The SM&CR aims to reduce harm to consumers and strengthen market integrity by creating a system that enables firms and regulators to hold people to account. As part of this, the SM&CR aims to:

• encourage staff to take personal responsibility for their actions
• improve conduct at all levels
• make sure firms and staff clearly understand and can show who does what

This will mean a raft of work for smaller firms and they will need to start immediately to get ready for the early December deadline.

Things to consider include

  • The Senior Management Functions (SMFs)
  • Statements of Responsibilities (SoRs)
  • The Duty of Responsibility
  • Fit and proper requirements
  • Impact on firm governance and structure
  • Holding more than one SMF
  • The 12-week rule
  • Outsourcing under the SMR
  • Applying conditions when approving Senior Managers
  • Prescribed Responsibilities (PRs)
  • Who the PRs should be given to
  • Dividing and sharing a PR
  • Partnerships under the Senior Managers Regime
  • What are ‘Reasonable Steps’?

As well as

  • Mapping APR functions to SMFs
  • Function mapping for Core and Limited Scope firms (including branches)
  • What to do if your current controlled function is not listed
  • Exception – individuals to perform the SMF9 – Chair role
  • Executive Chairs
  • New and applications in progress (including transfers of existing approved individuals)
  • New approvals to be effective before Commencement
  • New approvals to be effective after Commencement
  • Moving an existing approved individual into a SMF that doesn’t map from their APR function
  • Applications in progress at Commencement
  • Interim applications for roles which won’t be approved under the SM&CR

We have worked on this with small banking organisations (as well as big ones) and can help. Call us on 0207 097 1434


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