On  Wednesday 4th September, delegates from across the financial services industry attended our breakfast briefing for an exploration of what firms are doing as they make their final preparations for SMCR implementation.

In a departure from the usual briefing format, delegates were invited to participate in a series of roundtable discussions, each of which was chaired by a representative from various areas of the firm, including our financial services, employment, disputes and regulatory compliance practices. The event was a huge success, with delegates enthusiastically sharing their experiences of complying with the new regime and the challenges this has presented.

Whilst the event was run under Chatham House rules, we set out below some of the insights gained from the briefing.

Certified staff are a challenge 

Over 50 percent of delegates stated that the greatest difficulties experienced in looking to comply with the regime have actually been in respect of certified staff. A lack of guidance on conducting fitness and propriety assessments alongside a lack of clarity in regards to transitional arrangements have all contributed to this.

But firms are broadly on-track…

Over 70 percent of delegates stated that, notwithstanding the challenges that the SCMR regime is presenting, they still expect to be broadly in compliance by 9 December 2019.

Reasonable steps are important

Over 75 percent of delegates stated that in order to get senior managers comfortable with the new regime, they are dedicating a significant portion of their efforts to considering what would be reasonable steps in various different circumstances.

Other issues that emerged from the roundtable discussions included general concerns about the territorial application of the regime, the time required for the FCA to manage applications and the impact of SMCR on outsourcing.

SMCR – are you ready?

The extension of the SMCR is now only three months away from its implementation date of 9 December 2019. If you do not yet have your implementation plans in place, we can help. We offer a range of solutions, including our SMCR toolkit which provides access to a range of key documents that are needed in order to implement the SMCR in their business.

We can offer access to our SMCR hub which is available on the NRF Institute. With briefings, videos, events, and blog posts, the hub provides a comprehensive understanding of the new expectations for anyone preparing for, and needing to comply with, the new regime.

For more information, contact Rebecca Haynes.