On July 26 2017, The Financial Conduct Authority (FCA) published its long-awaited Consultation Papers to extend the Senior Managers and Certification Regime (SM&CR) to all FCA regulated firms, currently estimated to be 47,000.
The FCA has recognized that it is not appropriate to apply SM&CR in exactly the same way as it did for banks and insurers.
Instead, it will be applied in a proportionate and flexible way to the wider industry; considering different business models and governance structures including its application to EEA and non-EEA branches.
Therefore, the FCA will apply the SM&CR in three tiers:
Next Steps
Firms or individuals wishing to comment on the Consultation Papers are required to do so by November 3 2017. The FCA expects to issue its policy statement in Summer 2018 with commencement at some point thereafter in 2018.
Experts at Duff & Phelps can help you assess the consultation paper relative to your firm, and can provide assistance with planning and strategic thinking for the implementation of the SM&CR.
