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UK Government and Regulators Launch SMCR Review

The tone of the papers suggests that a fundamental reform of the Regime will be unlikely. On 30 March 2023, the PRA and the FCA published a joint Discussion Paper (FCA DP23/3 and PRA DP1/23) seeking feedback on the...more

UK FCA Publishes Detailed Plans for New Consumer Duty

FCA makes clear that it expects a cultural shift in how firms focus on consumers. On 7 December 2021, the FCA published its second Consultation Paper (CP21/36) on introducing a new Consumer Duty....more

PRA Publishes Findings on Its Evaluation of the SMCR

The PRA has released a largely positive report, along with nine follow-up actions and recommendations on the SMCR for PRA-regulated firms. Key Points: ..There is no need for major changes to the SMCR. ..There are...more

SMCR: FCA Updates Expectations on Fitness and Propriety Assessments and Conduct Rules Training

The FCA has provided updated guidance on the SMCR for solo-regulated firms, with new information on good and bad practices in two key areas. On 14 August 2020, the FCA updated its webpage on the Senior Managers and...more

FCA Consults on SMCR for Benchmark Administrators

The FCA has published a Consultation Paper that sets out proposed rules for the SMCR for benchmark administrators. Key Points: ..The SMCR for benchmark administrators (that perform no other regulated activities) will...more

FCA Warns of ‘Significant Weaknesses’ in Firms’ Implementation of the Conduct Rules

All firms should take note of the FCA’s latest feedback on SMCR implementation. In its latest piece of feedback on firms’ implementation of the SMCR, the FCA indicated that firms must improve their implementation of the...more

FCA Confirms SMCR Optimisations

The FCA has published final rules confirming amendments to the SMCR, and final rules for solo-regulated firms. Key Points: ..The FCA has confirmed that the Head of Legal does not require approval as a Senior Manager,...more

FCA Consults on Further Amendments to the SMCR

The FCA seeks to clarify the position of the Head of Legal and the scope of the Client Dealing Function. Key Points: ..The FCA is proposing to exclude the Head of Legal from the scope of the Senior Managers...more

Regulators Publish Final Rules on SMCR Extension

The FCA and the PRA have published their Policy Statements, setting out final rules on the SMCR regimes for insurers and FCA solo-regulated firms. Key Points: ..The FCA has announced that the extended SMCR will apply to...more

Individual Accountability for PE Executives Continues to Increase Under Legal and Regulatory Changes

Corporate accountability has been a key focus for UK legislators and regulators since the credit crisis, as authorities have taken action against corporate failings. In our view, this focus is evolving to emphasise individual...more

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