News & Analysis as of

Senior Management Regime (SMR) SMCR

A&O Shearman

D&I in FS: new rules and guidance on non-financial misconduct

A&O Shearman on

The FCA is focused on reducing non-financial misconduct to enhance the reputation of the UK financial services sector. Spurred on by positive levels of engagement with its 2021 discussion paper, the FCA’s latest consultation...more

Hogan Lovells

UK SMCR: HMT Call for Evidence and FCA/PRA Discussion Paper

Hogan Lovells on

On 30 March 2023, the FCA and PRA published a joint discussion paper which seeks views on the operational aspects of the Senior Managers and Certification Regime. Alongside this, HM Treasury also published a Call for Evidence...more

A&O Shearman

What UK readers couldn’t get enough of in 2022 - the top five blog posts revealed

A&O Shearman on

2022 saw a big shift in the geo-political climate and a bedding in of the new hybrid working world. These two developments are reflected in the blogs our subscribers were most interested in reading. Readers remain focused on...more

Akin Gump Strauss Hauer & Feld LLP

FCA Clarifies Its Position on 'Significant SYSC Firm' Dilemma

The FCA announced earlier yesterday that it will consult on amending the definition of 'Significant SYSC Firm' to ensure that no firms will be subject to the enhanced rules of the Senior Managers and Certification Regime...more

Hogan Lovells

SMCR for Financial Market Infrastructures: HM Treasury Consultation

Hogan Lovells on

HM Treasury has launched a consultation on creating a Senior Managers and Certification Regime (SMCR) for financial market infrastructures (FMIs) supervised by the Bank of England (BoE). ...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

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

Proskauer Rose LLP on

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

Hogan Lovells on

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

FCA and PRA Statement on SM&CR and COVID-19: Expectations of Dual-Regulated Firms

Latham & Watkins LLP on

UK Regulators announce new measures after acknowledging firms affected by COVID-19 will need to keep their governance arrangements under review. On 3 April 2020, the FCA and the PRA released a statement announcing several...more

Morgan Lewis

SM&CR and COVID-19: UK Regulators’ Expectations

Morgan Lewis on

The UK Financial Conduct Authority and Prudential Regulation Authority have published statements setting out their expectations of dual-regulated and solo-regulated firms on their senior managers and certification regime...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

BCLP

Funds First seminar – responding to a regulatory incident in the new world of SMCR

BCLP on

At our recent Funds First seminar we shared some technical and market issues and updates on the Senior Managers and Certification Regime (SMCR) and the FCA’s current cross-sector focus on culture. This briefing sets out some...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

WilmerHale

UK Financial Conduct Authority Proposes to Exclude the Head of the Legal Function From the Senior Managers Regime

WilmerHale on

On 23 January 2019 the UK Financial Conduct Authority (FCA) published Consultation Paper CP19/4 which, amongst other things, proposes to exclude the Head of the Legal function from the Senior Managers Regime (SMR). The...more

BCLP

The journey from SIMR to SMCR for insurers

BCLP on

Insurers, reinsurers and managing agents (which we will refer to in this article as “insurers”) will be fully within the scope of the Senior Managers and Certification Regime (“SMCR”) regime from 10 December 2019, following a...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

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