This is the ninth 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 eight 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
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. All but one of the executive directors also perform 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 implementation project and, with the implementation date of 9th December 2019 rapidly approaching, it is nearing conclusion. The senior managers and certification staff have been identified, and the required updates to documentation for the SM&CR to be implemented have been put in place. The fitness and propriety of both the senior managers and the certification staff have been assessed. Training plans have been devised for the senior managers and the training for the certification staff has been designed and is currently being delivered. The necessary amendments have been implemented to the existing systems and controls to embed SM&CR into business as usual. All that remains is to put in place training on the conduct rules for the small number of staff at Smith & Cromer that are neither senior managers nor certified staff.
Training for Conduct Staff
Sam Carr, the project lead for SM&CR implementation, only has a handful of staff left to train on the conduct rules. The senior managers’ conduct rules training has already been delivered and certified persons’ conduct rules training is currently happening. That leaves just four staff at the firm that will require training on the new SM&CR conduct rules, and there is a transition that means Sam has up to 9 December 2020 to deliver the required training.
Given that Sam has already engaged a firm of external compliance training specialists to deliver ‘lunch and learn’ sessions to the certified persons at the firm, she considers it would be both consistent and cost effective to add a further session for the conduct rules staff. She also concludes that it is sensible to get this done before the end of the year. The target group have seen all of the other training for the SM&CR going on around the office, so to provide a special session for them at this stage is more in line with the inclusive approach taken at Smith & Cromer.
In consultation with the external compliance training firm, Sam decides on a two-stage approach for the staff.
Download this instalment of our SM&CR case study series for details of Sam's approach...
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.