As the date draws closer for implementation of the Senior
Manager and Certification Regime (SMCR) across asset management
firms, HR's attention is turning to the impact of the new
regime on regulatory references.
Brought in to replace the approved persons regime and to prevent
'recycling' of individuals with poor conduct records
between firms (protected by a series of settlement agreements),
these references must follow a form set by the financial services
regulator, the Financial Conduct Authority (FCA), and be requested
each time a new employee is appointed to a certified or senior
manager role.
There are a series of detailed questions the firm providing a
reference must complete, the crux of which is whether it concluded
the individual was not fit and proper to perform a certified or
senior management function, and whether the individual was subject
to any disciplinary action.
