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

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

  • SM&CR—essentials for banks and PRA-designated investment firms
  • Background to the Senior Managers and Certification Regime
  • Statutory framework of the SM&CR
  • PRA and FCA approach to the SM&CR
  • Rules and guidance
  • Consultation Papers and Policy Statements
  • SM&CR banking firms
  • The Senior Managers Regime
  • Senior management functions
  • Other overall or local responsibility function (SMF18 and SMF22)
  • More...

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

BREXIT: 11pm (GMT) on 31 December 2020 (‘IP completion day’) marked the end of the Brexit transition/implementation period entered into following the UK’s withdrawal from the EU. Following IP completion day, key transitional arrangements come to an end and significant changes begin to take effect across the UK’s legal regime. This document contains guidance on subjects impacted by these changes. Before continuing your research, see: Brexit and financial services: materials on the post-Brexit UK/EU regulatory regime. See also: Brexit and financial services—the temporary permissions regime (TPR) — Senior Managers & Certification Regime (SM&CR) and the TPR.

As a result of failings in the financial services sector which contributed to the 2008 financial crisis, the UK Parliamentary Committee on Banking Standards (PCBS) was established in 2012 to consider professional standards in the UK banking sector. The PCBS recommended improving genuine accountability in firms. In response, the Senior Managers and Certification Regime (SM&CR) was created to increase individual accountability and raise standards of governance in order to help restore consumer confidence in the financial services sector and strengthen market integrity. The introduction of the SM&CR marked a fundamental shift in the PRA and FCA’s approach to regulating individuals.

The constituent parts of the SM&CR are:

  1. Senior Managers Regime (SMR): Capturing, as a minimum, members of a firm’s board, the SMR requires the PRA or FCA to

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