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01 August 2017

SMCR extension to all FCA firms

The Senior Managers and Certification Regime (SMCR) was born out of the recommendations of the Parliamentary Commission on Banking Standards following its review of the 2008 financial crisis and is part of the FCA’s focus on the culture and governance within the firms it regulates.

The FCA want firms to have, or develop, a ‘culture of accountability’ at all levels and senior individuals to have clearly defined responsibilities for which they are personally accountable. The SMCR replaces the Approved Persons Regime. This took effect for banks in March 2016 and will be extended to the remaining FCA firms by the end of 2018 (insurers have been subject to a slightly different process, but are also affected by the extension of SMCR).

We have produced an introduction to the likely shape of the extended SMCR which reflects our experience of the banking and insurance regimes, the ‘proportionate’ approach outlined in the FCA consultations launched on 26 July 2017 and the various preceding FCA statements and publications.

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For more information please contact David Hicks on +44 (0)20 7427 6647  or at