This is the third instalment in our SM&CR case study series, designed to help you prepare for the implementation of the FCA’s Senior Managers & Certification Regime (SM&CR). This series follows fictitious firm Smith & Cromer Limited’s project to implement the Regime with the process and tips being released to you throughout the year.
- Read the first two instalments?
- Watched our one-minute explainer video – SM&CR in a Nutshell?
If not, visit the dedicated SM&CR website homepage to access these resources.
If you are up to date, read on...
About our case study firm
Remember Smith & Cromer Limited is a fictional solo-regulated firm active in the wholesale markets with 25 staff in total, including 20 approved persons. There are five executive directors and two non-executives. All but one of the executive directors also performs the customer function under the approved persons regime. The compliance function and the MLRO function are both performed by Sam Carr, who is not a director of the firm.
Sam is steering the SM&CR project plan and, after identifying the senior managers at the firm, those that need to be certified as fit and proper, and the remaining staff, it is now time to consider the documentation updates that will be necessary for the SM&CR to be implemented.
SM&CR documentation updates
Documentation to be updated and drafted
Sam has carefully reviewed relevant guidance from the FCA’s website and, after discussion with Smith & Cromer’s retained compliance consultants, she has come up with three key areas to consider:
- Statements of Responsibilities
- Code of Conduct
- Responsibilities Map
Download the latest instalment of our SM&CR case study series to read how Sam approaches this stage of the SM&CR implementation plan...
If you have any questions about this case study or if you are looking for support with preparing your own firm for the SM&CR contact us now.