One key governance aspect of the FCA’s 2019/20 Business Plan is the extension of the Senior Managers & Certification Regime (SM&CR) to all solo-regulated firms in December this year. SM&CR is seen by the FCA as a “catalyst for change and an opportunity to establish healthy cultures and effective governance in firms by encouraging greater accountability and setting a new set of personal conduct”. A core aim is to reduce consumer harm and strengthen market integrity by focusing on people, behaviour and personal accountability. This means a healthy culture should be instilled by the leadership of firms at all times and that consistent standards of good personal conduct for all staff are maintained.
Embedding the SM&CR into the DNA of firms will be a key challenge for firms’ compliance teams.
We are working with a number of firms with their SM&CR projects, and our SM&CR Academy earlier this week included a compliance breakout session which discussed practical considerations around the regime’s implementation. To access the recording please click here.
We also have an SM&CR toolkit which includes:
- Template project plan covering all required work streams
- Pro-forma Statements of Responsibilities based on generic role profiles
- Pro-forma Management Responsibilities Map
- Employment law clause bank (to change employment contracts)
- Online training module on the conduct rules
- Template fit and proper policy and certification procedures
- Template breach reporting policy
- Template policy for senior managers to access independent legal advice
- Template notifications policy
- Template handover policy and handover certificate
- Template “living will” to assist senior managers document their reasonable steps
- Template regulatory references policy
- Template whistleblowing policy
- List of changes required to the employee handbook
- Template record keeping and documentation policy
To view a demo of the SM&CR Toolkit and register for further information please click here.
