SM&CR—policy development and key dates
SM&CR—policy development and key dates

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

  • SM&CR—policy development and key dates

In June 2013, the Parliamentary Commission for Banking Standards (PCBS) published its report Changing Banking for Good, which set out a number of recommendations for legislative and non-legislative actions to improve professional standards and the overall culture in the UK banking industry. This was later followed by legislation in the form of the Financial Services (Banking Reform) Act 2013 (FS(BR)A 2013), which aimed to replace the Approved Persons Regime (APR) for banks, building societies, credit unions and Prudential Regulation Authority (PRA)-designated investment firms with a new regulatory framework for individuals.

On 7 March 2016, the Senior Managers and Certification Regime (SM&CR) replaced the APR in relation to UK banks, building societies, credit unions and PRA-designated investment firms, as well as UK branches of non-UK firms. On 10 December 2018, the SM&CR was extended to insurers and re-insurers (although additional requirements apply to Solvency II and large non-directive firms, ie, those with assets over £25m). The application of the SM&CR to insurers replaces the separate Senior Insurance Managers Regime (SIMR) which itself had replaced the APR in March 2016 in relation to UK-incorporated firms falling within the scope of Solvency II, including insurance and reinsurance firms.

The Senior Managers Regime (SMR) aims to ensure that senior managers can be held liable for any misconduct that falls within their remit of responsibilities, while the Certification Regime

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