BVRLA Compliance Officer, Hayleigh explains the importance of preparing for the new FCA Senior Managers & Certification Regime, launching in December.
Can anyone remember what was at the top of their long list of projects for 2018 at the start of the year? I know I can’t – but what I can remember, though, is that December felt like a lifetime away! But it was with us in a flash and I was soon surrounded by greeting cards and Christmas decorations in the local supermarket.
The Financial Conduct Authority’s new Senior Managers & Certification Regime (SM&CR) comes into play from 9th December this year, and although this currently feels a long way off, it will be here before we know it.
The FCA are introducing this new regime with a view to “reducing harm to consumers and strengthening market integrity by making individuals more accountable for their conduct and competence”. It will work on a three-tier structure and what will be required of you will depend on the tier your firm falls under.
I recently attended a SM&CR-related roundtable event hosted by the FCA, and their overarching message was loud and clear: that firms need to get moving on preparations NOW, as culture and process changes will take time to embed.
The sooner you get preparations underway, the better. It will quickly become apparent what changes need to be made within your organisation to ensure compliance. As always, you will have the BVRLA team on hand to provide advice and guidance. In fact, we will be publishing a factsheet in Q1-2019 and will also host a webinar to support members with the transition.
The FCA believes that firms should be able to get ready for the new regime themselves, without having to pay someone to do it for you, but only if you give yourself enough time and don’t wait until the last minute.
Here’s a few tips to help you get ready…
- Make good use of the literature and guidance available on the FCA website. There’s lots available, so you may find it takes you some time just to read through and understand. I’d recommend using the Guide for FCA Solo Regulated Firms.
- Understand how the guidance applies to your firm. The FCA website guidance on SM&CR includes a Firm Checker Tool, which is really helpful in establishing your firm’s type as a starting point.
- Ask yourself some readiness questions to establish any actions you may need to take. The FCA Guide for FCA Solo Regulated Firms also includes a SM&CR readiness checklist (Annex 2) which will help you get to grips with the key information you’re going to need.
If you’ve already started preparing for SM&CR and want to share your experiences, views or suggestions, please feel free to get in touch with me.
Best foot forward…
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