On 18 December 2020, the following were published:
- Joint PRA and FCA December 2020 update – SM&CR and COVID-19: our expectations of dual regulated firms.
- FCA December 2020 update – SM&CR and COVID-19: our expectations for solo-regulated firms.
- FCA December 2020 update – Approved Persons Regime and COVID-19: our expectations.
In April 2020, the PRA and FCA set out their expectations to help dual-regulated and solo regulated firms apply the Senior Managers and Certification Regime (SM&CR) following the exceptional circumstances arising from the COVID-19 pandemic. In particular, the regulators offered some additional flexibility in the application of the SM&CR rules to these firms. As firms have adapted to the impact of the pandemic over the past few months, the regulators’ current expectation is that firms’ application of the SM&CR rules returns to normal. Firms should be aware that some of the previously available provisions providing flexibility will end on 7 January 2021 and that the relevant modifications by consent will end after 30 April 2021. The regulators have provided further detail on what this means in their updates.
In June 2020, the FCA set out its expectations to help firms using Appointed Representative (AR) arrangements apply the Approved Persons Regime (APR) during the COVID-19 pandemic. The FCA has now issued an update stating that some of the previously available provisions will end on 7 January 2021 and that the relevant modifications by consent will end after 30 April 2021