By 9 December 2019 all solo-regulated firms will have to be compliant with the FCA’s new Senior Manager & Certification Regime (SMCR) and with the SMCR stocktake report published by the FCA last month (FCA SMCR Stocktake Report) it’s clear that conduct, culture and accountability are still firmly in the spotlight.
To produce the report, the FCA spoke to organisations that have already implemented SMCR during the first wave and it has to be said that the findings appear to be generally positive. They noted 'the industry has made a concerted effort to implement the regime' and that although there were 'challenges' around initial implementation, many firms have overcome this and are working to embed the regime below Senior Manager level.
Over the past year we have been working with a number of firms on their SMCR preparations and have to echo the views of the FCA, many of our clients are a long way down the road and have, amongst other things, reviewed and reorganised reporting lines, agreed or drafted statements of responsibilities and, where necessary, created their Management Responsibilities Maps.
We are also aware of and are supporting a number of firms who have a programme of training in the diaries as people return from holiday over the coming days, driving the roll out and education across their Senior Manager communities.
Clearly SMCR will impact different size and types of firm in different ways and the level of preparedness across the sector will also differ accordingly, however with many in the sector really getting to grips with it the last thing firms want to risk is being the 'odd one out' and having the FCA knocking on the door in the run up to Christmas!
If you would like any more information in relation to preparing for SMCR and how we are helping firms to ensure they are compliant come 9 December, get in touch with Jonathan Pepper.