Ep.16: Saeed Patel, Director of Product Strategy at KRM22

To simply implement this new regime, using current toolsets, poses a risk to firms falling short to the requirements of the SM&CR regime, Saeed Patel of KRM22 says. In this podcast, Patel discusses the Senior Managers and Certification Regime (SM&CR or SMCR) with IBS Intelligence Reporter Sunniva Kolostyak.

The UK regime, which is being extended to almost 50,000 organisations, will come into effect on 9 December, and Patel suggests affected companies should go through the following checklist for compliance:

SM&CR checklist

• Define your firm type: limited scope, core, enhanced
• Brief board-level and other senior executives likely to be subjected to SM&CR
• Create implementation plan including activities, timelines, resourcing requirements, dependencies and available technology solutions
• Identify which senior managers will have prescribed responsibilities and prepare responsibility statements
• Identify individuals performing certified functions who will require certification by the firm
• Ensure employment contracts, management structures and job specifications reflect current responsibilities
• Notify the FCA of any changes to certified individuals with prescribed responsibilities and submit senior manager’s FCA applications for approval
• Update internal appraisal and recruitment processes to include Fit and Proper assessments and appropriate background checks
• Ensure handbook policy and procedures comply with regulations
• Raise company SM&CR awareness through training and company-wide roll out