This is the fifth instalment in our SM&CR case study series, designed to help you prepare for the implementation of the FCA’s Senior Managers & Certification Regime (SM&CR). This series follows fictitious firm Smith & Cromer Limited’s project to implement the Regime with the process and tips being released to you throughout the year.
- Read the first four instalments?
- Watched our one-minute explainer video – SM&CR in a Nutshell?
If not, visit the dedicated SM&CR website homepage to access these resources.
If you are up to date, read on...
About our case study firm
Remember Smith & Cromer Limited is a fictional solo-regulated firm active in the wholesale markets with 25 staff in total, including 20 approved persons. There are five executive directors and two non-executives; one of whom performs the role of Chair at the firm. All but one of the executive directors also performs the customer function under the Approved Persons Regime. The compliance function and the MLRO function are both performed by Sam Carr, who is not a director of the firm.
Sam is steering the SM&CR project and has already identified the senior managers and certification staff, and considered the documentation updates that will be necessary for the SM&CR to be implemented and assessed the fitness and propriety of the senior managers who will be taking on the senior manager functions. This has enabled a training plan for the senior managers to be devised.
SM&CR Training for Senior Managers
Sam and her CEO have agreed that what is required is a training session for the senior managers on the conduct rules that will apply under the SM&CR, with particular focus on the Senior Manager Conduct Rules. The planned training will be delivered by a seasoned ex-practitioner and trainer who is well placed to tailor and deliver the session for an audience that is predominantly board level. In this instalment, we will roll back a little and look at the various options considered for the senior managers’ training and how Sam and Smith & Cromer’s CEO reached their decision on the training provider.
Download this instalment of our SM&CR case study series to see Sams next steps and key takeaways from this stage in the SM&CR Implementation Plan...
If you have any questions about this case study or if you are looking for support with preparing your own firm for the SM&CR contact us now.