The Senior Managers and Certification Regime (SM&CR) – currently applied to banks and insurers – will be extended to all FCA solo regulated firms from December 2019, when it will replace the Approved Persons Regime (APR). For insurance intermediaries, this is the biggest change to regulatory governance since 2005.
There are significant differences between APR and SM&CR, particularly in relation to obligations for:
- A statutory duty of responsibility for senior managers
- The Certification Regime,
- The wider application of Conduct Rules.
Its intention is for clear and transparent accountability at the most senior levels of any firm whilst extending responsibility for customer outcomes down through a firm.
“…promote positive behaviours that reduce harm”
“…improve individual accountability and the awareness of conduct issues across the firm”
FCA Guide to SM&CR for solo regulated firms
Much of SM&CR is the natural evolution of good, documented, governance. Well-run firms, who have complied with APR, will already have many of the processes, effective performance management and a conduct culture of accountability in place.
This course will equip individuals to manage the transition through understanding SM&CR: what is new and different, what is actually similar and what is a realistic gap analysis of where the firm is now and what must be place by December.