The FCA has published proposals to extend the Senior Managers and Certification Regime (SMCR), which already applies to banks, to other financial services firms. The new rules, which are designed to make individuals more accountable for their actions, will affect insurance intermediaries and their employees.
We have prepared:
Our experience from working with our banking and insurance clients suggests that projects to implement the SMCR should begin now rather than waiting for the outcome of this consultation. We have suggested some next steps for firms to be thinking about now.
Key points include:
- The SMCR replaces the Approved Persons Regime (APR).
- Most firms will need to meet certain core standards, although some will benefit from a lighter touch regime.
- For a few, larger firms, the compliance burden will be significantly greater.
The FCA's consultation ends on 3 November 2017. The new requirements are expected to apply from some time in 2018.
For more on SMCR in the Financial Services sector, See our briefing here.
The contents of this publication are for reference purposes only and may not be current as at the date of accessing this publication. They do not constitute legal advice and should not be relied upon as such. Specific legal advice about your specific circumstances should always be sought separately before taking any action based on this publication.
© Herbert Smith Freehills 2021