Experience with dual regulated firms shows that you should not underestimate the considerable requirements across all areas of your firm to implement the regime. It is important firms are clear on the steps they must go through for each of the regimes, key implementation activities are shown below.
To assist firms we have created an SMCR Toolkit which includes an implementation guide as well as a full suite of templated policies, registers and other documents.
 

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 Senior Manager Regime  Senior Manager Regime

1. Identify SMFs – who is performing a defined Senior Manager role, who can be grandfathered across and whether additional FCA approvals are required

2. Allocating responsibilities – agreeing the distribution of Prescribed Responsibilities as defined by the regime and ensuring no gaps or splitting of responsibilities

3. Statements of Responsibilities – working with SMFs to agree their role and wider responsibilities (does not apply to Limited Scope Firms)

4. Updating role profiles and job descriptions clarifying delegated authorities is a particularly important part of this

5. Management responsibilities map (MRM)* – single overarching map that records the arrangements, reporting lines and responsibilities of individuals across the firm

6. A ‘Handover’ policy* – to facilitate handover for incoming/outgoing Senior Managers

*Enhanced Firms (recommended for Core Firms)

Certification Regime v2 Certification Regime

1. Identifying the staff requiring certification – likely to require an in-depth analysis of regulatory permissions and the scope of each individual’s role

2. Understand employee lifecycle changes needed – how the regime impacts recruitment, onboarding, performance management and exit processes

3. Issuing certificates – process and system for fitness and propriety assessments and issuance of annual certificates

4. Providing regulatory references - making sure your systems and processes record failures to meet fitness and propriety and conduct rule breaches so that references are accurate

Conduct Rules v2 Conduct Rules

1. Conduct Rules training - for all levels of staff. May involve one to one or classroom training and is expected to include some form of e-learning

2. Breaches of conduct rules – defining what constitutes a breach and the process for monitoring and reporting

3. ‘Reasonable steps’ framework – ensuring the elements are in place to support Senior Managers in meeting their obligations

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We can offer an end to end managed programme, support in discrete elements or you can select one of our three defined services that have been tailored to support organisations of different size, maturity and complexity - supported by our technology platform Compliancy.SMCR.

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