SM&CR: Are You Up-To-Date And Prepared?

Author:Mr Robert Hill and Ruth Bonino
Profession:Clyde & Co

If you are a solo-regulated FCA firm, you will be transitioning into the Senior Managers & Certification Regime on 9 December this year. CEOs of relevant firms were sent reminders earlier this year encouraging them to prepare. We can help you in that process - so please read on to find out how (including links to our latest webinar and briefing note). We also set out below a quick summary of the key not-to-be-missed announcements so far this year. Find out below how we can help you prepare.

Clyde & Co's employment and regulatory teams can help you in 3 key areas:

HR training Staff training Drafting Train HR teams on the basic principles of SM&CR and how the conduct rules may affect, or give rise to disciplinary matters. Provide specially designed training aimed at different levels of your organisation (from the Board through to other "conduct rules staff") on what the new regime means to them and the potential personal consequences for breaching the conduct rules. Review and draft amendments to contracts of employment and relevant policies, such as fitness & propriety and disciplinary policies to take account of the conduct rules. At Clyde & Co, we have considerable experience in advising in this area: such as when banks and insurers transitioned to the SM&CR and SIMR respectively in 2016, and again when insurers transitioned to SM&CR in December last year. More recently we have advised many financial services firms in connection with their up-coming transition process.

Other resources you may find useful

Clyde & Co webinar: Are you SMCR ready? Updated guide: the extension of SMCR to FCA regulated firms Updating you on what's happened so far this year

On 26 July, the FCA published a Policy Statement (PS19/20) with the final...

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