Senior Managers and Certification Regime—management responsibilities map
Produced in partnership with Nigel Brahams, Partner of Fox Williams LLP
Senior Managers and Certification Regime—management responsibilities map

The following Financial Services guidance note Produced in partnership with Nigel Brahams, Partner of Fox Williams LLP provides comprehensive and up to date legal information covering:

  • Senior Managers and Certification Regime—management responsibilities map
  • Who needs an MRM and when is it required?
  • What should be included in the MRM?
  • Names and responsibilities
  • Statements of responsibilities
  • Management and governance arrangements
  • Allocation and division of responsibilities
  • Details of functions
  • Matters reserved to governing and management bodies
  • Interaction of management and governance arrangements
  • more

STOP PRESS: The Senior Managers and Certification Regime (SM&CR) was extended to insurers regulated by the FCA and PRA from 10 December 2018, replacing the Senior Insurance Managers Regime (SIMR). This Practice Note will be updated shortly to reflect these changes.

Who needs an MRM and when is it required?

Firms covered by the Senior Managers and Certification Regime (SM&CR) are required at all times by the Senior Management Arrangements, Systems & Controls (SYSC) part of the Financial Conduct Authority (FCA) Handbook (SYSC 4.5.4 R), and also by the Prudential Regulation Authority (PRA) Rulebook, Allocation of Responsibilities Rule 7.1, to have in place a comprehensive and up-to-date management responsibilities map (MRM). The MRM describes a firm’s management and governance arrangements under the SM&CR, including the roles taken by the various individual Senior Management Function Managers (SMF Managers).

The MRM is intended to help the firm and the regulators satisfy themselves that the firm has a clear organisational structure, as well as to provide transparency to the regulators, such that they can identify the right person within an organisation to approach in the case of any issues. According to the PRA, the MRM should be seen as a valuable component of a firm’s internal corporate governance documentation and processes. It describes an MRM as the governance equivalent of a business plan or