Senior Managers & Certification Regime (SM&CR)
The Financial Conduct Authority introduced SM&CR for all regulated firms in December 2019. This framework requires significant resources and planning to promote a culture of accountability at all levels within your organization.
SM&CR Applies to Three FCA Firm Categories
Different requirements apply based on your firm's classification
Limited Scope
Basic SM&CR requirements for smaller firms
Core
Standard framework for most regulated firms
Enhanced
Comprehensive requirements for larger institutions
Key Components of the Regime
Understanding the structural changes from the Approved Persons framework
Senior Management Functions (SMFs)
Replaces Control Functions with senior personnel appointments
- Senior Managers require Statements of Responsibility
- Core and Enhanced firms must assign mandatory Prescribed Responsibilities
- Clear accountability at executive level
Certification Regime (CR)
Annual assessment of key personnel fitness and propriety
- Firms determine which Certification Functions are necessary
- Certification valid for maximum 12 months
- Annual reassessment required for all certified individuals
Conduct Rules
Minimum behavioral standards for all relevant staff
- Two-tiered structure: Individual and Senior Management levels
- Applies to Senior Managers, Certification Functions, and non-executive directors
- Excludes only ancillary staff
Prescribed Responsibilities
Mandatory accountability assignments for Core and Enhanced firms
- Clear allocation of regulatory responsibilities
- Documented in Statements of Responsibility
- Regular review and updates required
How MEMA Can Help
Comprehensive SM&CR implementation support tailored to your firm
Dedicated Advisor
Personal regulatory advisor assigned to your firm
Fact-Finding
Comprehensive business assessment and gap analysis
Documentation
FCA-compliant policies, procedures, and statements
Ongoing Support
Application support and compliance monitoring
Promoting a Culture of Accountability
SM&CR forms part of the FCA's Culture and Governance priority, designed to promote the development of a "culture of accountability at all levels" within regulated organizations. This framework ensures clear responsibility allocation and enhances individual accountability.
Clear Responsibilities
Enhanced Accountability
Improved Governance
Need SM&CR Implementation Support?
Our regulatory experts will guide you through every step of SM&CR compliance
📞 Phone: 0330 133 0811
📧 Email: contact@memaconsultants.com