Coronavirus (COVID-19)—implications for the Senior Managers and Certification Regime (SM&CR)

The following Financial Services practice note provides comprehensive and up to date legal information covering:

  • Coronavirus (COVID-19)—implications for the Senior Managers and Certification Regime (SM&CR)
  • Senior manager responsibilities
  • SMF applications
  • Temporary arrangements for SMFs—the 12-week rule
  • Solo-regulated firms
  • Dual-regulated firms
  • Furloughing SMFs
  • Notifications and documentation
  • Certification requirements and Conduct Rules
  • Solo-regulated firms
  • More...

Coronavirus (COVID-19)—implications for the Senior Managers and Certification Regime (SM&CR)

The Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA) have issued statements setting out their approach to the Senior Managers and Certification Regime (SM&CR) for regulated firms in light of coronavirus (COVID-19). This Practice Note provides an overview of the implications of coronavirus for the SM&CR.

In April 2020, the FCA and the PRA issued a joint statement on their approach to the SM&CR for dual-regulated firms in light of coronavirus. The FCA also issued a statement setting out its expectations for solo-regulated firms. The regulators said they recognised that firms directly affected by coronavirus needed to keep their governance arrangements under review, and they announced a number of specific provisions for firms. For more information about the SM&CR, see the following Practice Notes:

  1. SM&CR—essentials for banks and PRA-designated investment firms

  2. SM&CR—essentials for solo-regulated firms

  3. SM&CR—application to insurers

  4. SM&CR—essentials for claims management companies

In addition, the FCA issued a statement in June 2020, setting out its expectations to help benchmark administrators and firms using appointed representative (AR) arrangements apply the Approved Persons Regime (APR) during coronavirus. The FCA recognised that firms may need longer periods of temporary arrangements if, for example, an approved person is absent because of coronavirus, or if recruitment to replace an approved person has been delayed due to the pandemic.

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