SM&CR – 6 things you should have done before the 9th December

Today marks the deadline for firms preparing for the Senior Managers and Certification Regime – 3 years after its rollout for banks and insurers, the regulation has been extended to 50K more companies in the UK.

We’d like to think that all advisers are on the ball and are now sitting back, confident that they have completed everything on the SM&CR checklist – however, if that’s not quite the case, we’ve popped below a list of 6 things you should have done by today (9th December).

  1. Established which regime you fall under – This helps you understand what your responsibilities are when implementing the regulation. To find out which regime you fall under, check out the FCA’s online firm type checker tool here.
  2. Established who will hold Senior Manager Functions and identified what their prescribed responsibilities are – A single person can hold more than one responsibility, as long as they are the most appropriate person to carry the responsibility.
  3. Carried out criminal record checks – This only applies to those who have not previously held a Senior Manager Function. You can choose to carry one out on every individual if you like, but it only needs to be done at this point on newly appointed Senior Managers.
  4. Created a Statement of Responsibilities for Senior Managers – This needs to be in written form and kept on file. These do not need to change in any specific period, such as annually, but if the individual holding the Senior Management Function changes or the job description, then you will need to have altered them accordingly.
  5. Completed training on the new Conduct Rules – Both Senior Managers and Certification staff need to have received training on, and comply with the Conduct Rules, additionally, Senior Managers also need to have completed Senior Manager Conduct Rules training. This training should also highlight the potential consequences of a breach.
  6. Changed job descriptions and contracts – You may have needed to amend the job descriptions you have given and the contracts you have with your staff, to reflect the new responsibilities they have.

If you’re still unsure on what you should have done to prepare for SM&CR then check out our Resources Page.

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