SMR&CR

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On November 29, the UK’s Financial Conduct Authority (FCA) published a consultation paper on applying the Senior Managers Regime (SMR) to benchmark administrators. (For more information on the Senior Managers and Certification Regime, or SM&CR, please see the July 28, 2017 edition of the Corporate & Financial Weekly Digest.)

SM&CR already applies to banks and insurers, and will apply to most other UK financial services firms as of December 9. Because benchmark administrators only began to be supervised by the FCA in January 2018, the SMR will apply to them starting December 7, 2020. This gives these firms one extra year to prepare for the regime.
Continue Reading SM&CR to Apply to Benchmark Administrators

On January 23, the UK Financial Conduct Authority (FCA), published a consultation paper on optimizing the senior managers and certification regime (SM&CR) (for further details on the SM&CR, see the March 11, 2016 edition of the Corporate & Financial Weekly Digest). Its proposals intend to help firms adjust to the SM&CR and to identify some of the rules which need to be revised, as currently drafted in the Individual Accountability (Amendment) (No 1) Instrument 2019.
Continue Reading FCA Consults on Optimizing the SM&CR and Proposes Excluding Heads of Legal From Senior Managers Regime

On December 13, the UK Financial Conduct Authority (FCA) published three consultation papers (CPs) on the transition from its existing Approved Persons Regime (APR) to the new Senior Managers and Certification Regime (SM&CR).

The CPs follow the FCA’s July 2017 consultation papers, which consulted on extending the SM&CR regime to all regulated firms (including both FCA solo-regulated firms and insurers) (for further information, please see the Corporate & Financial Weekly Digest of July 28, 2017). However, in these most recent consultations, the FCA accepts that proportionate approaches are required to extend the SM&CR to different firms.
Continue Reading FCA Consults on Transitioning Firms and Individuals to SM&CR

On October 3, the UK Financial Conduct Authority (FCA) published a discussion paper (Discussion Paper) on the application of the UK Senior Managers Regime (SMR) to persons responsible for the legal function of a UK regulated firm.
Continue Reading FCA Publishes Discussion Paper on Firms’ Legal Function Under the Senior Managers Regime