Where are we now?

Perhaps it’s a data breach, or maybe you’ve seen a sudden spike in complaints. Whatever it is that attracts the FCA’s attention, you can be sure that questions will be asked about who was responsible and what reasonable steps could’ve been taken to prevent it.

This is where your Senior Managers and Certification Regime (SMCR) arrangements will be scrutinised. If you can’t demonstrate that the regime has been effectively embedded, with all staff able to articulate their accountabilities and responsibilities, regulatory repercussions could quickly follow.

The FCA has repeatedly said that its work around cultural transformation and governance, with the regime at its core, will continue throughout 2020 and beyond, even if there's if there's a global pandemic!

Likewise, if we learnt anything from how the regime was embedded into the banking sector in 2016, it’s that SMCR compliance is an ongoing exercise. Changes to operational processes and controls presented specific challenges that quickly hindered progress. Learn from their mistakes and make sure your approach is bulletproof.

As you know, because of the impact Covid-19 has had, the FCA extended the Certification Regime deadline for solo regulated firms to the 31st March 2021. That might seem like a long time away but it's proof that the regulator will only continue to focus on assuring that all firms are compliant. We also expect future regulation and guidance to consider the core SMCR principles – culture really is at the heart of the regulator's agenda.

The resources in this guide will take you through some of the key things you need to consider post-SMCR implementation and why assuring your approach is so important.

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