To simply implement this new regime, using current toolsets, poses a risk to firms falling short to the requirements of the SM&CR regime, Saeed Patel of KRM22 says. In this podcast, Patel discusses the Senior Managers and Certification Regime (SM&CR or SMCR) with IBS Intelligence Reporter Sunniva Kolostyak.

The UK regime, which is being extended to almost 50,000 organisations, will come into effect on 9 December, and Patel suggests affected companies should go through the following checklist for compliance:

SM&CR checklist

Define your firm type: limited scope, core, enhanced
Brief board-level and other senior executives likely to be subjected to SM&CR
Create implementation plan including activities, timelines, resourcing requirements, dependencies and available technology solutions
Identify which senior managers will have prescribed responsibilities and prepare responsibility statements
Identify individuals performing certified functions who will require certification by the firm
Ensure employment contracts, management structures and job specifications reflect current responsibilities
Notify the FCA of any changes to certified individuals with prescribed responsibilities and submit senior manager’s FCA applications for approval
Update internal appraisal and recruitment processes to include Fit and Proper assessments and appropriate background checks
Ensure handbook policy and procedures comply with regulations
Raise company SM&CR awareness through training and company-wide roll out

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