In just one week’s time, on 9th December 2019, the Senior Manager & Certification Regime (SM&CR) will come into effect.
The SM&CR replaces the Approved Persons Regime, changing how people working in financial services are regulated. The aim of the SM&CR is to reduce harm to consumers and strengthen market integrity by making individuals more accountable for their conduct and competence.
Here at Broker Network, our Member Service teams have been working together to make sure that Members are all ready for the new regime. And we’ve put together a checklist of everything you need to do before next week. By the 9th December, your brokerage should have:
- Received contact from the FCA with its assessment of your SM&CR category, either Limited Scope, Core or Enhanced, to determine how SM&CR applies to your firm
- Identified who will be a Senior Manager within your firm
- Completed the necessary forms (if applicable) to amend your current Approved Persons, so these AutoMap across to the new Senior Management Function (SMF) in the correct way
- Completed a Statement of Responsibility for each Senior Manager
- Allocated to the relevant Senior Manager and clearly included in their Statement of Responsibilities the Prescribed Responsibilities applicable to your firm
- Trained Senior Managers & Certification staff in the Conduct Rules, ensuring they understand how the rules apply to their roles
- Identified the individuals that require Certification
- HR processes in place which now incorporate annual fitness and propriety checks for Senior Managers and Certification Staff
- Included within your recruitment processes the new Regulatory Reference Requirements
- Appropriate processes to obtain Criminal Record Checks and registered your firm to the Disclosure and Barring Service (DBS)
- Considered how all other staff members, excluding ancillary staff, will be made aware and trained on the Conduct Rules, so they are informed as how these rules apply to their roles.
If you’re a Broker Network Member, our dedicated SM&CR Toolkit on the Hub gives you access to documentation, training and guidance. To access it on the Hub, click here.
If you’re not part of Broker Network and would let to find out more about Membership, please get in touch.