News & Analysis as of

Senior Management Regime (SMR) Senior Managers

BCLP

UK regulators and Bank of England to pool considerable powers and resources to advance D&I

BCLP on

Yesterday’s joint Discussion Paper (DP21/2) published by the Bank of England, Prudential Regulation Authority (PRA) and Financial Conduct Authority (FCA, together “the regulators”) on “Diversity and inclusion in the financial...more

Hogan Lovells

SMCR Directory of certified and assessed persons – have you submitted your data?

Hogan Lovells on

The Financial Conduct Authority (FCA) is contacting thousands of firms across various sectors that appear to have missed the 31 March 2021 deadline for submitting “Directory person” data. ...more

Morgan Lewis

SMCR: Full Implementation for Solo-Regulated Firms Delayed to 31 March 2021

Morgan Lewis on

The UK Financial Conduct Authority recently published Policy Statement 20/12, which sets out the final rules on the extension of the Senior Managers and Certification Regime implementation deadlines for the certification...more

Morgan Lewis

FCA Releases Guidance to Assist Solo-Regulated Firms in Fitness and Propriety Assessments, Staff Training

Morgan Lewis on

The UK Financial Conduct Authority recently closed its consultation (CP20/10) to extend the deadline for solo-regulated firms to conduct their first fitness and propriety assessments of certified staff and train all staff on...more

Akin Gump Strauss Hauer & Feld LLP

Extension of the Senior Manager and Certificate Regime Implementation Periods for Solo-Regulated Firms to March 2021

On 30 June 2020, the Financial Conduct Authority (FCA) announced proposals designed to provide breathing room to solo-regulated firms (meaning those governed solely by the FCA) in respect of the implementation of certain...more

Proskauer Rose LLP

SMCR – Top Priorities for 2020/21

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Originally published on February 24, 2020. Updated as of July 1, 2020. The UK senior managers and certification regime ("SMCR") overhauled the accountability regime for individuals working in UK financial services firms...more

Hogan Lovells

SMCR: UK FCA extends implementation periods for solo-regulated firms

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The UK Financial Conduct Authority (FCA) has extended the deadline for solo-regulated firms to undertake their first assessment of the fitness and propriety of their certified persons under the senior managers and...more

Latham & Watkins LLP

Senior Manager Responsibilities in the Ongoing COVID-19 Situation

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Following the large-scale changes and challenges faced by firms during the initial phase of COVID-19, firms are beginning to consider what their operating model will be in the next phase and over the longer-term. For...more

A&O Shearman

UK Conduct Regulator Publishes Consultation on Extension of Senior Managers Regime to Benchmark Administrators

A&O Shearman on

The U.K. Financial Conduct Authority has published a consultation paper seeking feedback on its proposals for the extension of the Senior Managers’ Regime to benchmark administrators. The FCA’s SMR was originally implemented...more

Latham & Watkins LLP

FCA Consults on SMCR for Benchmark Administrators

Latham & Watkins LLP on

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

Jones Day

Turning Tides in FCA SMCR Enforcement: Easier Targets, Non-Financial Misconduct, Changing Priorities

Jones Day on

The Situation: The Financial Conduct Authority ("FCA") is extending the Senior Managers and Certification Regime ("SMCR") to FCA solo-regulated firms on 9 December 2019 and has also released a number of statements in relation...more

Morrison & Foerster LLP

SM&CR for Solo-Regulated Firms: Are You Ready?

Morrison & Foerster LLP on

The UK regulatory Senior Managers and Certification Regime (SM&CR) came into force in March 2016 to replace the UK Financial Conduct Authority (FCA) Approved Persons Regime (APR) for firms that are subject to dual regulation...more

Proskauer Rose LLP

Senior Managers and Certification Regime - Extension to All FCA Authorised Firms is Coming

Proskauer Rose LLP on

On 9th December 2019, the Senior Managers and Certification Regime (SMCR) will replace the current Financial Conduct Authority (FCA) Approved Person Regime for practically all FCA authorised firms, including alternative...more

A&O Shearman

The UK’s Expanded Senior Managers and Certification Regime: Key Issues and Action Plan for Brokers, Advisers and Asset Managers

A&O Shearman on

The expanded Senior Managers and Certification Regime (SM&CR), which comes into force on December 9, 2019, extends the framework regulating individuals charged with running certain financial institutions. The Banking SM&CR,...more

Akin Gump Strauss Hauer & Feld LLP

Senior Managers and Certification Regime

The commencement date of 9 December 2019 for the extension of the Senior Managers and Certification Regime (SMCR) to solo-regulated firms is fast approaching. The SMCR will replace the existing Financial Conduct Authority...more

A&O Shearman

Marking three years of the UK’s Senior Managers and Certification Regime

A&O Shearman on

Last month, we were joined by over 200 clients for a seminar which marked the first three years of the UK’s Senior Managers and Certification Regime (SMCR) being in force. During the first three years of the SMCR being in...more

Morgan Lewis

FCA Issues Final Guidance on Key Issues Ahead of SMCR Extension

Morgan Lewis on

The Financial Conduct Authority (FCA) has recently published its final guidance on statements of responsibilities, responsibilities maps, and its policy statement on the new FCA directory for financial services workers, ahead...more

BCLP

SMCR for FCA-solo regulated firms

BCLP on

The FCA recently released the latest in a long series of papers relating to the Senior Managers and Certification Regime (“SMCR”). FCA Consultation Paper CP19/4 sets-out new measures designed to “optimise” the SMCR ahead of...more

White & Case LLP

FCA Senior Managers and Certification Regime – CP 19/4

White & Case LLP on

General counsels at FCA regulated firms will no doubt be relieved to see that in its latest Consultative Paper published yesterday the FCA has rowed back from its previous suggestion that "Head of Legal" should be a senior...more

Latham & Watkins LLP

FCA Consults on Further Amendments to the SMCR

Latham & Watkins LLP on

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 Regime. ...more

Katten Muchin Rosenman LLP

One Year to Go Before SM&CR Applies to All FCA-Regulated Firms

The Senior Managers & Certification Regime - As a reaction to the financial crisis of 2008/2009 and following the subsequent review of the financial services industry, UK Parliament decided to replace the discredited...more

A&O Shearman

UK Prudential Regulator Fines Senior Managers For Failing to be Open and Cooperative

A&O Shearman on

The Prudential Regulation Authority has announced that it has imposed financial penalties on two senior managers for failing to be open and cooperative about an enforcement action into the U.K. subsidiary of a Japanese bank...more

Dechert LLP

Asset Management Regulatory Roundup - March 2018 - Issue 5

Dechert LLP on

A compact summary of the most recent regulatory developments relevant to the UK asset management industry.This issue includes details of proposed changes to the Financial Services Register to accommodate the Senior Managers...more

Dechert LLP

FCA Publishes Proposed Rules to Extend Senior Manager & Certification Regime to All Financial Services Firms

Dechert LLP on

The UK’s Financial Conduct Authority (FCA) has published proposed rules to extend the senior manager & certification regime (SMCR) to all financial services firms....more

Akin Gump Strauss Hauer & Feld LLP

Financial Conduct Authority Consults on Senior Managers and Certification Regime

On 26 July 2017, the UK Financial Conduct Authority (FCA) published its much-anticipated Consultation Paper (CP 17/25) “Individual Accountability: Extending the Senior Managers & Certification Regime to all FCA firms.” The...more

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