Okay, so let’s say you’re ready for the new senior managers regime on 9th December 2019. You have identified those impacted, and they are all prepared, you’ve even got a plan for ongoing compliance oversight and monitoring of the new regime.
It might seem like plain sailing from here, but with the flurry of activity to implement the Senior Managers Regime as part of SMCR ahead of the implementation deadline, be careful not to fall into the trap of forgetting about the all-important Certification Regime.
“But Senior Managers are the ones performing the key roles requiring FCA approval, so there’s more to be done.”
Not really. The Certified population can be much larger in most firms, so there is much more to do. You are required to check and certify that they are fit and proper to perform their role and provide Conduct Rules training ahead of the implementation date of 9th December 2019. In addition, embedding this cultural change, especially with so many people, could take much effort and time.
“Right, but we’ve got another 12 months after the implementation date for Senior Managers, so we’ll just deal with it then.”
Not exactly! Whilst firms have 12 months from the start of the new regime to certify individuals that are performing a Certification Function, they must still identify them by day one. You will also need to ensure you have collected all additional evidence that will allow you to assess an individual’s fitness and propriety prior to 9th December 2020. As we all know, in the world of regulation, a year is not a very long time! Your solution is to start thinking about it now, alongside the senior managers regime.
“This sounds complicated.”
It doesn’t have to be, although you do need to bear in mind the different facets of SMCR implementation, as well as training that will need to be tailored for each role.
“This is a big job, it’s going to take a lot of resource and time!
It may do, so you’d be wise to consider this. But don’t worry, as we can be there to help plan, communicate and support your implementation, including the training you may need to get the Certification Regime implemented correctly and on time. Even if you’re already well underway, we can still help provide you with the assurance you need to be confident all bases are covered.