"With less than 270 days to go until the implementation of the SM&CR regime, advisory firms should be undertaking the work required in order to ensure they meet the new standards."
Advice firms are currently regulated under the FCA’s Approved Persons Regime however this will be replaced by the SM&CR from the 9th December 2019.
Under the regime, senior management must evidence good culture and ethics and are also expected to write their own ‘Statement of Responsibility’ to confirm the personal responsibility they are taking for the conduct of their firm. Senior managers must also certify annually that certain individuals within the firm are fit and proper, and competent to perform a controlled function.
The guide sets out where the duty of responsibility lies, where firms should start in terms of their preparations for the new regime and the immediate actions that are required.
Bob Hunt, chief executive of Paradigm Mortgage Services, commented: “With less than 270 days to go until the implementation of the SM&CR regime, advisory firms should be undertaking the work required in order to ensure they meet the new standards.
“The SM&CR is all about leadership and culture within a regulated advisory firm. The clear expectation is that business owners take the lead in this and, not only take responsibility for their own actions but also leading their entire firm. It also means that every member of staff who interacts with a customer or performs a role that could affect the outcome of any advice or services provided to that customer must meet a certain standard of behaviour set by the business owners, and that they adhere to the conduct rules at all times.
“This Guide on the SM&CR not only provides an overview of the requirements but it also steers firms in the right direction so they can begin work immediately and ensure they meet the 9th December deadline. Given this is an industry-wide issue, we’re very pleased to make this available to all intermediary firms, as part of our ongoing support to firms ahead of SM&CR."
