SMCR – Are you ready?

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9 December 2019

As the latest piece of FCA regulation (SMCR) comes into force today (9th December) it raises the question, are you ready?

This regulation appears to have passed a few people by as we were still getting calls from firms wanting help with its implementation last week.

To assist firms we have put together an easy to follow checklist aimed at Core firms.  This will allow you to assess your preparation for the SMCR requirements.

Activity Due Date Date of Completion
Review firms Senior Management Functions (SMFs) and confirm these are correct and to continue. By 24th Nov
Review firm’s existing procedures for recruitment to identify any gaps in due diligence, review role profiles for SMF’s By 9th Dec 19
Consider who currently has access to Gabriel/Connect and who may need access moving forward. By 9th Dec 19
Review organisational chart – To ensure this clearly shows who the firms SMFs are. By 9th Dec 19
Review prescribed responsibilities and allocate to senior managers By 9th Dec 19
Review other business activities responsibilities and assign to SMF’s By 9th Dec 19
Create Statements of Responsibilities for SMFs By 9th Dec 19
Define which roles within the firm need defining as certified and identify any induvial who will be certified By 9th Dec 19
Review firms Training & Company scheme to incorporate competency of SMFs and all certified functions. By 9th Dec 19
Identify Supervisors responsible for signing off certified staff, and ensure they have the necessary skills and understand the responsibility. By 9th Dec 19
Complete Conduct training for SMFs By 9th Dec 19
Complete Conduct training for certified staff and other staff caught under the conduct rules By 9th Dec 19
Issue Certificates for all certified staff By Dec 2020
Identify ancillary staff to whom the Conduct Rules will apply By Dec 2020
Complete Conduct rules training for all ancillary staff By Dec 2020

Policies and Procedures needed Due Date Date of Completion
Due Diligence procedures/questionnaire for onboarding of SMF/CF roles By 9th Dec 19
Referencing form meeting FCA guidelines By 9th Dec 19
Certificate to be issued annually By Dec 2020
Review/update HR referencing procedures to ensure these meet FCA requirements By 9th Dec 19
Review Fit & Propriety procedures to ensure that these meet requirements By 9th Dec 19
SMF handover procedures (enhanced firms only) By 9th Dec 19
SMF/CF induction process By 9th Dec 19
Senior managers register – must be kept up to date and retained for at least 6 years By 9th Dec 19
Certified staff register By 9th Dec 19
Conduct rules policy By 9th Dec 19

Over the last few months, we have helped many firms prepare for SM&CR implementation.  If you have a few things on this list that aren’t quite there yet, call us on 0161 521 8641.

Or if you’d like a printable version of the checklist, please email:

You can find more information on SMCR from FCA’s website.

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