The UK senior managers and certification regime
("SMCR") overhauled the accountability regime for
individuals working in UK financial services firms and has been in
force for just over two months now. The regime applied to all FCA
solo-regulated firms on 9 December 2019, but for most firms, there
is still work to be done. In this memo, we summarize the main
issues firms will need to focus on to ensure full compliance with
SMCR in 2020 and beyond. For further background and detail on SMCR,
see our previous memo
here.
1. The Certification Regime
The certification regime ("CR")
applies to employees whose role means it is possible for them to
cause significant harm to the firm, its customers or the market
more generally (also referred to as 'Certification
Functions'). Firms must check and certify that individuals
holding certification functions are fit and proper to perform their
role at least once a year. Firms must complete certification
assessments and issue
