The Senior Managers and Certification Regime (SM&CR, or SMCR) came into effect on 9 December 2019 impacting approximately 47,000 solo-regulated financial firms.
SM&CR is designed to improve accountability and enhance the focus on culture within financial services firms. The Financial Conduct Authority (FCA) implemented this regime for banks in early 2016 - and is now serious about enforcement.
The new regime may require substantial changes to your firm’s governance and culture. Firms now need to take stock of the policies, processes, and documentation that they have put in place.
Has the correct engagement taken place with individual employees to make the necessary changes that are required by the regulator?
Have your employees received bespoke SM&CR training on how it impacts their day-to-day roles?
ACA provides a comprehensive and practical suite of SM&CR solutions, designed to help firms and individuals review and maintain compliance against the directive. Our SM&CR services include post-implementation assurance reviews of your firm's current framework and on-going assistance with employee assessments and training.
Call us at +44 (0)20 7042 0560 to learn more
As part of ACA’s post-implementation assurance review services, we help you fully consider the direct and indirect impact of SM&CR on your firm, with a specific focus on organisational and cultural changes required to fully implement the new regime.
Our SM&CR post-implementation assurance service includes:
Including scheduled or tailored in-house sessions.
In the course of helping numerous firms implement their SM&CR programmes, we have observed six concerns:
Embracing a governance structure and culture
Determining prescribed responsibility and whether it should be collective or individual
Documenting and maintaining details of individual roles, including statements of responsibility, job descriptions and employment contracts
Conducting fitness and propriety assessments, regulatory references and criminal records checks
Aligning and maintaining record keeping requirements of compliance, HR and legal
Comprehending code of conduct breaches and disciplinary processes
ACA provides regular insights and viewpoints on SM&CR. Below are available resources you can read for additional information or guidance:
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