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Senior Managers & Certification Regime

The SMCR already applies to banks, for which it was introduced in 2016. It also applies to insurers, although they are working their way through a transitional period at the moment. From December 2019 the SMCR will begin to apply to almost every other firm that is regulated by the FCA.

For more information on the extension of the Senior Managers and Certification Regime to solo regulated firms, please click here

How can we help?

For banks and insurers operating under the regime, the SMCR continues to throw up challenges associated with:

  • how to properly assess whether and what Conduct Rules have been breached
  • determining the fitness and propriety of candidates being recruited,
  • determining the fitness and propriety of staff at the annual certification round, and those who are facing disciplinary processes.

Handling references under the new regulatory reference regime is also an area of particular concern, where we anticipate court and employment tribunal disputes.

We advise employers on all aspects of compliance with the regime, including on the recruitment and departure of senior staff. We also assist senior managers and certified staff to understand their own obligations and to deal with the challenges they may face. We advise both on an as-needed or project basis, and as part of an institution’s regular staff take-on programme.

Recent news, articles and deals:

Insurers hiring and employing certified staff under the SMCR - are your processes fit for purpose?more
The Senior Managers and Certification Regime – what do you need to do from 10 December?more
SMCR checklist: The countdown beginsmore
The Senior Managers and Certification Regime: What senior managers should expectmore
Calls for FCA to take charge on SMCR harassment rules - Helen Farr and Peter Wright quoted in Investment Weekmore
Law firm urges wealth advisers to be ready for SMCR - Joanna Chatterton and Peter Wright interviewed by Wealth Advisermore
Why SMCR and collegiate culture are at odds - Joanna Chatterton and Peter Wright interviewed by The Wealthnetmore
Chris Finney quoted in IFLR - SMCR extension could be culture shock for insurance sectormore
Joanna Chatterton writes for Insurance Age: The hidden sting in the SMCR regimemore
Joanna Chatterton and Chris Finney quoted in Insurance Times: SMCR – the ‘complicated’ regulation that has the potential to change employee culturemore
Chris Finney and Joanna Chatterton write for Insurance Business Magazine - The SMCR: are insurers prepared? more
A temporary reprieve on SMCR but forward planning will save time and money more
SMCR for insurers: Are you ready?more
Joanna Chatterton and Peter Wright write for Management Today: The City's new accountability rules risk unintended consequencesmore
Peter Wright quoted in Insurance Business Magazine: Don’t expect the FCA to be lenient with the SMCRmore
PRIMER: The Senior Managers Certification Regime – International Financial Law Review 15 March 2018more
The extension of the Senior Managers and Certification Regime to all financial services firms – application to UK limited liability partnershipsmore
An introduction to the extension of the Senior Managers and Certification Regime to all financial services firmsmore
Senior managers can mitigate risk by taking concerns to FCA immediately – lawyersmore
Financial services partner Peter Wright comments on Wednesday’s FCA announcementmore

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Who should I contact?


Peter Wright
Direct dial: +44 (0)20 7614 2680


Helen Farr
Direct dial: +44 (0)20 7614 2623


Chris Finney
Direct dial: +44 (0)20 7614 2614


Joanna Chatterton
Direct dial: +44 (0)20 7614 2617


Aron Pope
Direct dial: +44 (0)20 7614 2640


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