Five tips for what solo-regulated FCA firms should be doing to prepare for the Senior Managers and Certification Regime (SM&CR)

1. Know which rules apply

Not all firms are subject to the same rules. This further extension sees the regime split into three tiers:

Limited scope - Firms who already have exemptions under the APER, typically with fewer Senior Managers Functions (SMFs). Exempt from some baseline requirements.

Core - Firms that need to meet baseline requirements.

Enhanced - Firms whose size, complexity and potential impact on consumers or markets warrant more attention. These firms will have extra requirements such as Responsibility Maps.

2. Identify your SMFs and certificated individuals

The Senior Manager Regime (SMR) focuses on individuals who hold key roles and responsibilities – called SMFs, whereas the Certification Regime (CR) focuses on people whose job may have a significant impact on the firm, its customers and/or market integrity. Regulators need to approve these people individually, then the firm needs to allocate each with Statements of Responsibility.

3. Acceptance of responsibilities, regulatory referencing and ‘Fit and Proper’ assessments

All those allocated a SMF or Certificated Role must sign a declaration to agree to the responsibilities. Every role holder must also be evidenced as a certified Fit and Proper person to carry out the allocated duties and responsibilities. If they cannot be certified, then they cannot perform the role. You must assess the fitness and propriety of these individuals at least annually.

4. Understand responsibilities and be trained

It is not just your SMFs and Certified staff that need to understand the impact of the regime. Most staff within your firm will also need to undertake training in the Conduct Rules too. You should be prioritising the resources now needed for implementation e.g. people, procedures, processes and systems.

Within 12 months you will need to have completed the certification process and trained all non-SMF and non-certified staff on the Conduct Rules.

5. Create a Responsibilities Map (RM)

If your firm is subject to the Enhanced Regime, you must also produce and submit a RM.

To find out more about the SM&CR and how Access can support you, our on-demand webinar recording: 'Everything you need to know about SM&CR' is available to watch at your convenience.

We have all the tools you need to meet the demands of SM&CR

In addition to delivering eLearning and tracking CPD, we provide specialist tools to meet the additional demands, all driven from the accessLMS; these include:

• Allocate SMFs and Certificated Roles to individuals within your organisation.
• Create a workflow that ensures they sign a declaration to agree to the responsibilities.
• Record Fit and Proper assessments and allocate them to these individuals.
• Issue Annual Certificates of Fitness and Propriety.
• Map your SMF roles to create a RM for submission to the FCA.

Contact us to discuss your requirements.