Details of SMR & CR for the rest of the Financial Services industry, don’t hold your breath…

…Well at least not until the other side of Christmas. Last week at the WMA Insight 360 briefing the FCA gave its strongest signals yet that the Consultation on moving the remaining 52,000 firms (yes that many) to SMR / CR is likely to be in early 2017.

They suggested that the delay was due in part, to a desire to ensure that appropriate proportionality can be built in and their findings from their review of firms who moved over in March 2016 could be reviewed by firms who will be in the second tranche.

The headlines from the findings thus revealed to those of us present at the briefing were;

All firms’ submissions reached the minimum requirements however, responsibility maps were not as comprehensive or clear as the regulators would have liked and these will be the key tool, used by the regulator in their supervisory activities.

The advice from the FCA representatives was to begin planning now, as this will happen in 2018 and first step has to be allocation of responsibilities and focus on your current governance arrangements.

The full feedback analysis is now available on the FCA website. It can be found under Editors notes from the press release on the 28th September.

Access the full article here

Other speakers represented at the event, providers of support services as well as a firms who were part of the first tranche, gave some interesting insight to the challenges ahead. Of course these firms have only about 5 months now to put in place their Certification Regime. They admitted in some instances the biggest issue was the cultural shift and this will be helped by early engagement with those designated as Senior Management Functions. A common mistake in the early stages of preparation was to give the “job” of migrating a firm to SMR to Compliance or HR.  A representative firm admitted it quickly realised this wasn’t right, it has to led by the Senior Managers themselves who have to think through all aspects of activity and assign tasks accordingly.

Guidance from the panel on what firms should be doing now in addition to early engagement (this isn’t exhaustive but headline activities);

  • Establish your current controls and governance arrangements
  • Consider where handoffs occur and get your responsibilities mapped
  • Are all job descriptions in place, to include KPI’s and KCI’s
  • What systems will you need to help with the responsibilities mapping and subsequent changes to it?
  • Is your current T&C arrangements all encompassing – how will you test is someone is really fit and proper?
  • Do you have a budget for training SMF’s, Certificated Persons, remaining staff in the Code of Conduct rules

FSTP has provided a number of briefings to Senior Mangers of firms outlining the basic detail and helping firms establish their own “To Do List”.  If you are interested in hearing from Partners and Associates who have already helped firms get through the initial stages of preparation please contact us

Email –

Tel – 0203 178 4230

Julia Kirkland

Senior Partner