Senior Managers and Certification Regime
From December 2019 all consumer credit firms will be affected by the Senior Manager and Certification Regime (SM&CR) which replaces the Approved Persons regime. CCAS can help you interpret what these new rules mean for your business and prepare you for success.
SM&CR already applies to most other regulated financial services firms and the consumer credit sector is now included within this FCA regulation. In the other sectors affected by SM&CR we have seen personal fines and there is also the potential for custodial sentences. The consequences of not getting compliance right now press hard on the individual.
The main purpose of SM&CR is to drive Senior Managers and Certified Persons to take full and personal accountability for the regulatory conduct of the firms they oversee. It aims to encourage staff to take responsibility for their actions and improve conduct at all levels.
To begin with firms will need to identify what type of business they are – limited scope, enhanced or core – so they can understand how SM&CR applies. Previous approved persons functions will need to be mapped across to the new senior manager functions and firms will need to produce Statements of Responsibilities and Management Responsibility Maps.
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Many firms may also find that their management and governance arrangements need to be bolstered, enabling senior managers to have more effective oversight. This includes carrying out ‘fit and proper’ tests for senior managers, certified persons and anyone else in the business who can have an influence on customer outcomes or market integrity.
CCAS can guide you through this important transformation and ensure that you meet the requirements of SM&CR. We’ll help you manage change and build a robust framework that will stand up to FCA scrutiny as well as create competitive advantage.
Areas we can help with
- Statements of Responsibilities drafting
- SM&CR initial set-up
- Annual SMCR review
- New joiner/promotion SM&CR set-up
- Training for existing Approved Persons
- Training for all financial services staff
- Breach reporting
- Independent assurance testing
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