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.
How ready are you for SMCR? – take our online assessment to test your readiness
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
Get Advice Now
FCA Delays the Second Stage of the Implementation of parts of the Senior Managers Regime
On 30th June FCA announced a consultation on proposals to defer the deadline for implementing certain aspects of the second stage of the Senior Managers and Certification regime for solo regulated firms including consumer credit firms. FCA proposes to defer the deadline from 9th December 2020 to 31st March 2021 for: The extension of the …
October 5, 2020 at 11:40 am
FCA Issues draft new guidance regarding the fair treatment of vulnerable customers.
FCA has issued draft guidance on the fair treatment of vulnerable customers for consultation. The consultation period ends on 30th September. This guidance applies to all retail sectors and will be of particular relevance to consumer credit lenders. FCA expects firms to ensure that their employees have the relevant knowledge and skills to treat vulnerable …
October 5, 2020 at 8:26 am
New FCA Guidance on Forbearance during COVID-19
FCA has issued new guidance for lenders on how to treat customers adversely affected by coronavirus. Existing guidance is due to come to an end on 31st October so this new guidance will apply after that date. The guidance relates to customers who: have been granted 2 payment deferrals under the July guidance and remain …
October 5, 2020 at 8:14 am
Why firms need to stay in shape for SM&CR
The end of 2019 was marked for many consumer credit firms by a sprint to the line on 9th Dec. This was when the first stage of the SM&CR implementation was required. With only a short period of recovery firms are starting to think about getting in shape for the second stage at the end …
February 24, 2020 at 3:39 pm