The FCA has published proposals to replace the Approved Persons Regime with the Senior Managers and Certification Regime (SMCR) currently in force for banks. Almost all financial services firms will be required to comply with the SMCR. There is a separate consultation paper to extend the current Senior Insurance Managers Regime applicable to insurers to the full SMCR. Our recently published briefing contains a high level summary of the key elements of the new regime. The consultation ends on 3 November 2017.
As with the banks' implementation of the SMCR, we expect implementation projects will benefit from commencing at this stage in the consultation process rather than waiting for the Policy Statements. We have suggested some key next steps for firms to be thinking about at the end of our briefing. No precise date has been set for implementation, although the FCA and HM Treasury have previously stated 2018.
To read our full briefing please click here.
Key contacts
Karen Anderson
Consultant, London
Susannah Cogman
Partner, London
Elizabeth Head
Of Counsel, London
Clive Cunningham
Consultant, London
Marina Reason
Partner, London
Kelesi Blundell
Partner, London
Hywel Jenkins
Partner, London
Chris Ninan
Partner, London
Jon Ford
Partner, London
Simone Hui
Of Counsel, Hong Kong
Chee Hian Kwah
Director, Prolegis LLC, Singapore
Valerie Tao
Knowledge Lawyer, Hong Kong
Cat Dankos
Senior Regulatory Consultant, London
Disclaimer
The articles published on this website, current at the dates of publication set out above, are for reference purposes only. 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.