As the latest piece of FCA regulation (SMCR) comes into force today (9th December) it raises the question, are you ready?
This regulation appears to have passed a few people by as we were still getting calls from firms wanting help with its implementation last week.
To assist firms we have put together an easy to follow checklist aimed at Core firms. This will allow you to assess your preparation towards the SMCR requirements.
|Activity||Due Date||Date of Completion|
|Review firms Senior Management Functions (SMFs) and confirm these are correct and to continue.||By 24th Nov|
|Review firm's existing procedures for recruitment to identify any gaps in due diligence, review role profiles for SMF's||By 9th Dec 19|
|Consider who currently has access to Gabriel/Connect and who may need access moving forward.||By 9th Dec 19|
|Review organisational chart - To ensure this clearly shows who the firms SMFs are.||By 9th Dec 19|
|Review prescribed responsibilities and allocate to senior managers||By 9th Dec 19|
|Review other business activities responsibilities and assign to SMF's||By 9th Dec 19|
|Create Statements of Responsibilities for SMFs||By 9th Dec 19|
|Define which roles within the firm need defining as certified and identify any induvial who will be certified||By 9th Dec 19|
|Review firms Training & Company scheme to incorporate competency of SMFs and all certified functions.||By 9th Dec 19|
|Identify Supervisors responsible for signing off certified staff, and ensure they have the necessary skills and understand the responsibility.||By 9th Dec 19|
|Complete Conduct training for SMFs||By 9th Dec 19|
|Complete Conduct training for certified staff and other staff caught under the conduct rules||By 9th Dec 19|
|Issue Certificates for all certified staff||By Dec 2020|
|Identify ancillary staff to whom the Conduct Rules will apply||By Dec 2020|
|Complete Conduct rules training for all ancillary staff||By Dec 2020|
|Policies and Procedures needed||Due Date||Date of Completion|
|Due Diligence procedures/questionnaire for onboarding of SMF/CF roles||By 9th Dec 19|
|Referencing form meeting FCA guidelines||By 9th Dec 19|
|Certificate to be issued annually||By Dec 2020|
|Review/update HR referencing procedures to ensure these meet FCA requirements||By 9th Dec 19|
|Review Fit & Propriety procedures to ensure that these meet requirements||By 9th Dec 19|
|SMF handover procedures (enhanced firms only)||By 9th Dec 19|
|SMF/CF induction process||By 9th Dec 19|
|Senior managers register - must be kept up to date and retained for at least 6 years||By 9th Dec 19|
|Certified staff register||By 9th Dec 19|
|Conduct rules policy||By 9th Dec 19|
Over the last few months, we have helped many firms prepare for SM&CR implementation. If you have a few things on this list which aren’t quite there yet, call us on 0161 979 0726.
Or if you’d like a printable version of the checklist, please email: [email protected]
You can find more information on SMCR from FCA’s website.