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Extension of the Senior Managers and Certification Regime – Part II

Client memorandum | July 5, 2018

In 2015, we published a Client Memorandum reporting the announcement by the then Chancellor of the Exchequer, George Osborne, of the extension of the Senior Managers and Certification Regime (“SMCR”) from the banks and Prudential Regulation Authority (“PRA”) designated investment firms (amongst others) already subject to SMCR to the rest of the UK financial services industry.

The Financial Conduct Authority (“FCA”) has since consulted on the way in which SMCR should be applied to the rest of the sector, in substitution of the existing Approved Person regime, and on 4 July 2018 published a Policy Statement containing the “near-final” rules and a Guide seeking to assist firms in preparing for the new regime.

Although the implementation date is stated to be 9 December 2019, such that many firms may consider it too early to start taking action, now that the shape of the new regime is final (or, at least, near final), it is important that firms begin familiarizing themselves with how the regime will operate and commence preparations.

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This communication is for general information only. It is not intended, nor should it be relied upon, as legal advice. In some jurisdictions, this may be considered attorney advertising. Please refer to the firm’s data policy page for further information.