SM&CR is being discussed everywhere within the industry at the moment. It might feel familiar in the sense of more regulatory changes within the industry, however it should be discussed and certainly paid attention to as our colleagues in Banking have already implemented this regime and that means that pitfalls and issues have already been identified for those transitioning into the SM&CR regime in December 2019.
There are so many elements within the SM&CR, but with the regulator making clear the areas in which it expects to see improvements, based on the lessons learnt from the Banks.
A large part of SM&CR is making sure that firms have the right staff members in place for each role. Companies are responsible for making sure that they have appropriate people in place within the business. Achieving this is done through Fitness & Propriety checks.
The FCA has stated that it is not appropriate to have a subjective view from the line manager as to whether the member of staff is competent, but assessments should be objective against the agreed standards aligned to the role of the member of staff.
Fitness & Propriety also has the following requirements that must be satisfied:
- Honesty, Integrity & Reputation of the member of staff
- Competence and capability to carry out the role effectively
- Financial Soundness of the member of staff.
Click the link below to find out how we have been supporting firms with their preparations and how we could help to make your transition into SM&CR simpler with our guidance and support in evidencing that and effective and robust Fitness & Propriety assessments have taken place.