The deadline of 9th December 2019 is looming for all, with many firms still hurriedly compiling statements on capability. But The Senior Managers and Certification Regime (SMCR) is meant to be so much more than a tick box exercise.
The FCA already consider SMCR a business as usual requirement. However, for many the real impact of SMCR will not be known or recognised until they start their 2020 planning.
The ongoing requirement to ensure conduct training is available firm wide and tailored to the individual and the job they do, for some will prove onerous, for others impossible.
Of course, SMCR is about those on the Board. But it’s not just about those at the top – that’s where it starts and the buck stops – simply SMCR is about all we do and how we do it.
SMCR is about transparency, individual accountability and responsibility.
It is about cultural expectations, conduct, norms and behaviours.
It is about incentivisation, remuneration and progression.
It is about planning, prioritisation and perception.
For the successful and ambitious, the regime will become the firm wide go forward strategic tool and will determine the fate of the late adopter.
Here’s the Guide for FCA solo-regulated firms: https://www.fca.org.uk/publication/policy/guide-for-fca-solo-regulated-firms.pdf