The FCA has published proposals to replace the Approved Persons Regime with the Senior Managers and Certification Regime (SMCR) currently in force for banks. Almost all financial services firms will be required to comply with the SMCR. There is a separate consultation paper to extend the current Senior Insurance Managers Regime applicable to insurers to the full SMCR. Our recently published briefing contains a high level summary of the key elements of the new regime. The consultation ends on 3 November 2017.
As with the banks’ implementation of the SMCR, we expect implementation projects will benefit from commencing at this stage in the consultation process rather than waiting for the Policy Statements. We have suggested some key next steps for firms to be thinking about at the end of our briefing. No precise date has been set for implementation, although the FCA and HM Treasury have previously stated 2018.
To read our full briefing please click here.