SM&CR: Don’t forget about 31 March deadline!

This is a reminder that the remaining elements of the Senior Managers & Certification Regime (the SM&CR) for solo-regulated firms comes into force on 31 March 2021.

In Autumn last year, the FCA agreed to extend the deadline for implementing certain aspects of the SM&CR relating to the Certification Regime and the Conduct Rules from 9 December 2020 to 31 March 2021. This was to give those firms significantly affected by Covid enough time to fully implement the Certification Regime and to provide effective Conduct Rule training to its staff.

With 31 March deadline looming, what does this mean for you?

By 31 March, your firm must have completed the following tasks:

  • Task 1: Given Conduct Rule training to all staff members falling within the remit of the Conduct Rules who are not Senior Managers, Certification Employees or board directors (note that the Conduct Rules have applied to Senior Managers, Certification Employees and board directors since 9 December 2019 and therefore firms needed to have provided training to these individuals before this date);
  • Task 2: Assessed all individuals within the firm performing a Certification Function to ensure that they are fit and proper to carry out this function and these individuals must have been issued with a certificate by the firm; and
  • Task 3: Submitted information to the FCA about all Directory Persons so that they can appear on the Financial Services Register (“Directory Persons” include all Certification Employees, directors who are not performing a Senior Manager Function (both executive and non-executive directors) and other individuals who are sole traders or appointed representatives (including those within appointed representatives) who undertake business for clients and require a qualification to do so). Further details about how to submit this information to the FCA can be found on the FCA’s website by clicking here.

If you need any assistance with implementing the remaining SM&CR tasks within your firm, please get in touch with us:

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