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More on SMCR
In the United Kingdom, the Senior Managers and Certification Regime (SMCR) is designed to foster accountability among senior managers at financial services companies while elevating ethical and professional standards across the entire workforce.
The SMCR replaced the Approved Persons Regime (APR), which was previously applicable to key individuals in regulated entities. In the realm of insurance companies, this regime effectively superseded the Senior Insurance Managers Regime (SIMR), marking a significant shift in how financial services firms manage and hold their senior personnel accountable.
There are three key parts to the SMCR: Senior Managers Regime, Certified Persons Regime and Conduct Rules.
- Senior Managers Regime
This enforces a detailed and clear allocation of responsibilities between senior managers at each firm, with particular emphasis placed on key documents - 'Statements of Responsibilities' and 'Responsibilities Maps'. These help to record the distribution of responsibility to individual Senior Managers and to demonstrate to the regulators that there are no gaps or excessive overlaps. Always bear in mind that Senior Managers have a statutory duty of responsibility "to take reasonable steps to prevent regulatory breaches in the areas of the firm for which they are responsible".
- Certification Regime
This requires firms to check and confirm that employees performing roles relating to the firm's regulated activities are fit and proper, based on their qualifications, competence and personal characteristics. Once this has been confirmed, the firm needs to issue them with a certificate that must be renewed every year.
- Conduct Rules
This consists of a set of rules provided in the FCA's Code of Conduct Handbook (COCON) that covers all individuals:Senior Managers, Certified Persons and other employees.
How to comply with SMCR
1. Statement of Responsibilities - Set out the areas for which each Senior Manager is personally accountable
2. Responsibilities Map - This knits together the Statement of Responsibilities
3. Pre-approval for all Senior Managers - obtain this from the regulators before they carry out their roles
4. Duty of Responsibility - Ensure that Senior Managers understand their responsibilities and take reasonable steps to prevent regulatory breaches in their areas of responsibility
5. Identify all Certified Persons - These are all material risk takers
6. Fit and Proper Assessment - Of all Certified Persons, then re-assess on an annual basis
7. Training - Of all those who are subject to the Conduct Rules
SMCR Scope
SMCR rollout waves
The SMCR has been rolled out in three waves:
Wave 1: Banks, building societies, credit unions and large investment firms in March 2016 (updated July 2018)
Wave 2: Extended to insurance firms (those regulated by the FCA and PRA) in December 2018
Wave 3: The remaining financial services firms (otherwise known as 'solo-regulated firms' since they are regulated only by the FCA, not the FCA and PRA) came under the scope of this regime in December 2019.
SMCR categories
The third wave encompasses a wide variety of firms. To ensure that regulation is appropriate to their sizes and activities, the FCA has categorised them into three distinct groups:
Core: Firms that have to comply with the baseline requirements for solo-regulated firms
Limited scope: Firms that already had exemptions under the Approved Persons Regime, and are exempt from some requirements and require fewer senior management functions
Enhanced: Firms that have extra requirements - these are large, complex firms with potential impact on consumers or markets which warrant more attention from the FCA
SMCR & Duty of Responsibility
Senior Managers have a statutory duty of responsibility "to take reasonable steps to prevent regulatory breaches in the areas of the firm for which they are responsible". The FCA can take action against a Senior Manager (SM) where it can show that:
- There was misconduct by the SM's firm,
- At the time of the misconduct or during any part of it, the SM was responsible for the management of any of the firm's activities in relation to which the misconduct occurred, and the SM did not take such steps as a person in their position could reasonably have been expected to take to avoid the misconduct occurring or continuing.
The burden of proof for all these elements lies on the FCA. The SM does not need to show that they took reasonable steps - rather, it is for the FCA to prove that they did not. The defence against such action is if the senior manager can show that they took "the steps that are reasonable for a person in that position to take to prevent a regulatory breach from occurring".
Fitness and Propriety
The FCA must approve all senior managers, which assess whether they are fit and proper to perform the given function or responsibility.
Three key factors determine whether you are Fit and Proper:
- Honesty, integrity and reputation
- Competence and capability
- Financial soundness
When assessing a person's financial soundness, the FCA typically does not require a statement of the individual's assets or liabilities. Having limited financial means does not, by itself, impact the suitability of a person to perform a Senior Management Function (SMF).
When appointing a Senior Manager or Certified Person, firms must obtain regulatory references from all of their past employers from the past six years. This requirement also applies to the appointment of Non-Executive Directors (NEDs) who are not Senior Managers.
To meet this requirement, firms must keep records of disciplinary actions and fit and proper assessments for the past six years and avoid any agreements that would conflict with their disclosure obligations.
Want to learn more about SMCR?
This training aid is just one of 100+ free compliance training resources, including assessments, best practice guides, checklists, desk aids, eBooks, games, handouts, posters, training presentations and even e-learning modules!
You can keep up to date with SMCR best practices, industry insights and key trends across regulatory compliance, digital learning, EdTech, and RegTech news, by subscribing to our FCA Compliance Bulletin.
Our SMCR Compliance roadmap will help you navigate the compliance landscape supported by a comprehensive library of SMCR Courses and a fully integrated SMCR 360 Compliance Toolkit to streamline, unify and automate your processes.
Finally, SkillcastConnect provides a unique opportunity to network with other compliance professionals in a vendor-free environment, as well as exclusive benefits, including access to our free online learning portal.
Risk management needs to be continuously improved through learning and experience. It is vital that a risk management framework is updated as regulations change, risks are not static and best practices emerge.
