Is your SMCR project plan in place?

For firms that didn’t make the SMCR implementation deadline on 13 December 2019, all is not lost. 

There’s still time to deliver a robust, yet proportionate SMCR implementation in a few months. But you do need to get things moving. Some elements of the SMCR regime will be like ‘herding cats’ and can take more time than you expect.

To make your implementation a success, you need to stick to a project plan, identifying all the constituent workstreams and their key deliverables, with owners and timeframes for each. Our excel-based SMCR project template is tried and tested with our clients.

What does SMCR cover?

The Senior Managers and Certification Regime – known as SM&CR and SMCR – will be extended to all authorised firms to replace the Approved Persons Regime. In order to be proportionate the FCA has introduced different standards for different types of firm:

  • Core Regime: This is a baseline requirement which will apply to almost every firm.
  • Enhanced Regime: This will apply an additional set of requirements to larger firms (approximately 350) whose size, complexity and potential impact on customers warrants more attention.
  • Limited Scope Regime: This will apply to all firms that currently apply the Approved Persons Regime on a limited basis, for example sole traders.

SMCR itself covers three areas:

  • Senior Managers:  This covers anyone who undertakes a Senior Management Function. Each senior manager will have a Duty of Responsibility and a Statement of Responsibility but there is no need for a responsibilities map or handover procedures.
  • Certification Regime:  This covers people who are not senior managers but whose job means it is possible for them to cause significant harm to the firm or its customers. For example, algorithmic trading, client dealing, CASS oversight etc.
  • Conduct Rules: These basic rules apply to all employees except ancillary staff who do not perform a role specific to financial services. There are five high level obligations which apply to all, and an additional four obligations for senior managers.

The smaller your firm, the more straightforward your project will be. For many, a simple spreadsheet-based project plan is enough to properly record what needs to be done when, and by whom.

SMCR implementation deadline

Download our SMCR project template

SMCR implementation guidelines

Planning the SMCR implementation
The best way to get the ball rolling, is to put the SMCR Working Group in a room together and map out and agree the SMCR project plan. The Working Group should then meet regularly to review progress, identify any sticking points and continually refine deliverables and timelines. Delays should be escalated via the senior project sponsor, and any blockages dealt with accordingly.
Who is subject to the new SMCR?
The new regime affects almost everyone in the firm. Most staff will fall into line provided they are managed effectively. But it’s the personal accountability that Senior Managers will be expected to take on which can be the most painful, and it’s this process that needs the most attention. early buy in from your senior team is key.
Laying the right foundations for SMCR
The more administrative aspects of the regime such as the certification of fitness and propriety, conduct rule breach reporting, regulatory referencing processes, and so on should not be underestimated. But if you’re able to lay your project foundations as soon as possible, getting these right should cause fewer problems.

How we can help with your
SMCR implementation

Bovill has extensive experience of helping our banking and insurance clients with their SMCR implementation.

More recently we helped numerous solo-regulated clients in the run up to 9 December 2019.  We developed a full SMCR implementation toolkit and several support packages designed to help our smaller and less complex clients implement the regime in a robust, yet cost-effective manner.  For those larger or more complex clients, we provide a full and completely bespoke support service, tailored to meet your explicit needs and requirements.

Connect with Bovill

Maurice McDonald

Managing Consultant, Head of Conduct and Controls

Lisa Scott

Managing Consultant

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