Senior Managers & Certification Regime (SM&CR)

SMCR clarifies who in a firm has responsibility for undertaking key tasks, and that they possess appropriate skills and qualifications. Senior individuals are now accountable for decisions they make and oversee. Managers can be held to account if a firm is responsible for bad behaviour and demonstrates misconduct which leads to consumer detriment.

Benefits to consumers


CONSUMERS CAN NOW BE AWARE THAT SENIOR MANAGERS WITHIN FIRMS ARE PERSONALLY ACCOUNTABLE UNDER THE FINANCIAL SERVICES MARKETS ACT

CONSUMERS CAN TAKE COMFORT THAT FIRMS ARE ADDRESSING NECESSARY SKILL SETS AND QUALIFICATIONS OF SENIOR MANAGEMENT

Benefits to industry


TISA INITIATIVES RELATED TO SMCR ARE DESIGNED TO FACILITATE BENEFICIAL CHANGE

THE FORUM SHARES BEST PRACTICE AT INDUSTRY EVENTS AND VIA THE TISA WEBSITE, HELPING FIRMS TO IMPROVE THEIR BEHAVIOURS AND CULTURE

Benefits to UK economy


TISA ACTS AS A CENTRE OF EXPERTISE AND HELPS FIRMS WITH REGULATION AND UPLIFT SENIOR MANAGEMENT PRACTICES LEADING TO INCREASED MARKET INTEGRITY

TISA Groups & Resources

SM&CR Working Group

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SM&CR Technical Bulletins (MEMBER ONLY)

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SM&CR Publications

TISA Resources – Senior Managers & Certified People

Conduct Scenarios Concerning Senior Managers

The paper provide examples of situations where firms may need to consider if there has been a Conduct Rules breach or Fitness and Propriety concern for different types of staff under SM&CR.

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Living Will Document Template

This template may be useful to Senior Managers in meeting their reasonable step to ensure an orderly transition though firms may have provided their own individual templates to complete.

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Senior Manager Readiness Checklist

This quick checklist provides Senior Managers with a list of key areas they should be aware of and taking action on to meet their requiremnents under SM&CR.

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SM&CR – Obligations on the individual through the employee lifecycle (BAU processes)

This document is intended to provide individuals with information and considerations applicable to them for BAU processes of the employee lifecycle.

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Approach to development of BAU best practice in relation to ‘reasonable steps’

A Guide has been drafted to help Senior Managers and firms develop ‘reasonable steps’ frameworks that are appropriate and proportionate for their size and structure

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SM&CR Outsource Considerations for Senior Managers

This paper is intended to be used by Senior Managers in relation to oversight of oursource arrangements.

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TISA Resources – Conduct Rules

Conduct Scenarios Concerning Senior Managers

The paper provide examples of situations where firms may need to consider if there has been a Conduct Rules breach or Fitness and Propriety concern for different types of staff under SM&CR.

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Conduct Rules Training

This paper provides some useful hints and tips for firms to consider in their Conduct Rules training.

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Conduct Rules Case Studies

This paper briefly considers whether the behavior and action described in 4 case studies would be considered a Conduct Rules breach.

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Behaviours and the Conduct Rules / Fitness & Propriety breaches

This paper provides examples of behaviours that may result in a Conduct Rules or Fitness and Propriety breach for different types of staff under SM&CR.

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TISA Resources – Firms

SM&CR Ownership in BAU

We need to learn from the insights, best practices and common issues seen across the industry to ensure SM&CR is not lost within BAU when ownership is passed from the project to the business.

This document identifies 10 key areas of tension for SM&CR in BAU processing that need both upfront work and ongoing review.

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SM&CR – Obligations on the individual through the employee lifecycle (BAU processes)

This document is intended to provide individuals with information and considerations applicable to them for BAU processes of the employee lifecycle.

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SM&CR Culture Measurement Toolkit

A toolkit providing culture measurement tools for firms to modify and use as required to understand their current position and track progress towards any desired change or to view change as a result of the implementation of SM&CR.

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SM&CR Implementation Considerations

Key messages for firms going through SM&CR implementation from those who have survived the process.

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SM&CR Template Project Checklist & Outline Plan

A template project plan including all relevant areas of SM&CR for implementation including relevant dates for work planning to ensure readiness. This can be used and adapted as required by firms to use as their own project plan or to inform their SM&CR project.

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Areas of focus of the FCA in its Second Thematic Review – Certification Regime

In creating and implementing their own Certification Regime, considering BAU practices, firms may wish to consider the areas of focus of the FCA in its second thematic review.

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Creating and sustaining cultures of compliance (FCA)

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TISA Resources – Useful Links

FCA SM&CR main page

The Senior Managers and Certification Regime: Guide for insurers

The Senior Managers and Certification Regime: Guide for FCA solo-regulated firms

PS18/14: Extending the Senior Managers & Certification Regime to FCA firms – Feedback to CP17/25 and CP17/40, and near-final rules

GC18/4: Senior Managers and Certification Regime – Proposed guidance on statements of responsibilities for FCA firms