Hannah Manning

Solicitor, CMS

Hannah is an Associate in the Financial Services Regulatory team at CMS, with expertise spanning both contentious and advisory aspects of financial services regulation. She delivers strategic advice to firms and individuals on a broad range of regulatory matters, including governance, conduct, and market abuse issues. Hannah has significant experience guiding clients through complex FCA and PRA interactions, from supervisory enquiries to enforcement investigations and proceedings before the Upper Tribunal.

A core area of Hannah’s practice is the Senior Managers and Certification Regime. She advises on the practical implementation of the regime and supports clients throughout the Senior Management Functions (SMF) application process. Hannah assists with internal investigations and regulatory notifications involving Senior Managers, providing strategic guidance on accountability and individual conduct risk.

Contributed to

3

SM&CR—SMF interviews for regulatory approval

Practice Notes

This Practice Note outlines the use of interviews by the Financial Conduct Authority (FCA) and/or the Prudential Regulatory Authority (PRA) as part of the approval process to perform senior manager functions (SMF) at authorised firms under the UK regulators’ Senior Managers & Certification Regime (SM&CR). It outlines the circumstances in which the regulators are most likely to conduct interviews as part of the SMF approval process. It provides practical guidance for SMF candidates and their firms in preparing for interview, including common areas of focus during interviews, the regulators’ approach to interviewing external or internal SMF candidates and additional considerations for SMF candidates at dual-regulated firms.

Financial Services

SM&CR Checklist—preparing for SMF interviews

Checklists

This Checklist supports candidates preparing for interviews with the Financial Conduct Authority (FCA) and/or the Prudential Regulatory Authority (PRA) for approval to perform a senior manager function (SMF) under the UK regulators’ Senior Managers & Certification Regime (SM&CR).

Financial Services

SM&CR Checklist—SMF approvals: what to do when things go wrong

Checklists

This Checklist assists Senior Management Function (SMF) candidates and their firms to prepare for and address issues which may arise during the application process with the Financial Conduct Authority (FCA) and/or the Prudential Regulatory Authority (PRA) for approval to perform an SMF under the UK regulators’ Senior Managers & Certification Regime (SM&CR). It supports both candidates and firms (which submit the SMF application on behalf of the candidate) in identifying, managing and responding to issues which arise during or following an SMF interview, on receipt of a ‘minded to refuse’ letter, or where the regulator(s) refuse the application.

Financial Services