SMCR Handover Procedures, Living Will
A firm must ensure that it has appropriate and robust governance controls in place. Enhanced Firms are required to ensure that there are handover arrangements for an outgoing senior manager and that their role/ function and responsibilities are handed over to an incoming senior manager comprehensively. One of the key risks is how a firm ensures sufficient handover can occur in unexpected situations/ emergencies (e.g. if a senior manager is unexpectedly taken ill with a long-term illness or dies).
The most common approach is for firms to require their senior managers to maintain a “living will”; in essence a control document that is revisited frequently to note how issues that were ongoing at the time had been resolved or managed and where key documents can be found and how new issues were being addressed.