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Summary: Senior Managers and Certification Regime Rules 2018/19


Marks Sattin's Compliance and Financial Crime Recruitment Manager, David Phan, recently put together a summary of the FCA near final Senior Managers & Certification Regime rules published on the 4th July 2018. This extensive document is over 400 pages long and describes the key areas of change to be implemented over the next year and a half, with the deadline being 9 December 2019. 

The key areas of change:

Senior Managers Regime

The Senior Managers functions remain the same for the FCA only (not PRA), with the exception of:

• SMF18 (Other Overall Responsibility)
• SMF7 (Group Entity Senior Manager)
• SMF27 (Partner)

The functions have been further clarified in their handbook.

Certification Regime

The FCA have not made any further amendments to the Significant Harm Functions for the FCA, only authorised firms.

“Opt up” to an Enhanced Firm

Because of the large number of holding groups who have multiple legal entities and companies, the FCA have introduced a process for them to “opt up” on a voluntary basis to become an Enhanced Firm. Even though individually they do not meet the criteria for being an Enhanced Firm, this change will give them the opportunity to be recognised as one.

A new FCA Register

Currently the register only contains information on Senior Managers and no information on Certified Persons under the Certification Regime.

Download the full summary here.

For more information on the compliance market or if you're looking for a new challenge or an organisation seeking additional expertise, please email or call +44 (0)20 7747 9653.
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