The FCA Consults On SMCR Transitional Arrangements

On 13 December 2017, the FCA published consultation papers (CP17/40-42) that set out proposed transitional arrangements for the wider roll-out of the Senior Management and Certification Regime (SMCR). As will be well known, a version of SMCR has applied to Banks since March 2016.  In July 2017, the FCA set out (in CP17/25) for the first time its substantive proposals as to how the wider roll-out of SMCR would operate.  This was covered in our previous issue of Enforcement Watch " FCA consults on roll-out of SMCR to all authorised firms". 

These most recent consultations deal with the proposed transitional arrangements for these firms into the SMCR.  There are separate FCA and PRA consultations dealing with the application of SMCR to insurers, which we do not cover in this article.