Senior Managers & Certification Regime (SM&CR)

Enhance your governance, accountability and culture today with our Senior Managers Regime consulting

We Mitigate Your Personal and Firmwide Regulatory Risk

The Senior Managers & Certification Regime (SM&CR) was introduced to strengthen culture and governance in firms. The regime promotes greater individual accountability and enhanced standards of personal conduct. SM&CR is central to the culture and conduct agenda of the Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA).

Recently, firms have experienced changes in daily priorities, operations (including remote working), management control and Board oversight. You may have deferred risk governance and internal control processes and activities.

Financial services regulators regularly remind firms about ongoing SM&CR obligations and their expectations of firms and the Senior Managers Regime. More needs to be done to further embed SM&CR within organisations and mindsets.

Given the increased focus on individual accountability, Senior Managers must demonstrably exercise proper oversight and meet expectations to manage their own personal regulatory risk.

Our regulatory compliance specialists provide training and help firms assess their SM&CR compliance. We’ll enable you to further strengthen and embed your SM&CR framework.

How Xcina Consulting Can Help Your Business with Senior Managers & Certification Regime Compliance

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We support solo-regulated and dual-regulated firms’ need to ensure compliance. We will help you meet the requirements of the Senior Managers and Certification Regime in the following areas:

Providing independent assurance to the Board and Senior Managers on SM&CR frameworks and offering remediation. These frameworks cover:
- Policies, Statements of Responsibilities (SORs)
- Management Responsibilities Maps
- Fitness & Propriety assessment process
- Breach notification process and records
- Conduct Rules training process and records
- Recruitment process (including regulatory references).
Independent review, testing and remediation of reasonable steps framework. We ensure your documentation is fit for purpose, providing peace of mind to Senior Managers.
Assisting new Senior Managers in understanding their regulatory responsibilities and meeting their application requirements. (E.g. SORs, skills gap analysis, learning & development plan, induction programme).

SM&CR training is an opportunity for firms to embed the right culture. Our regulatory compliance specialists will develop one-off or ongoing SM&CR and Conduct Rules training programmes tailored to your team’s requirements.

Why Choose us for SM&CR Advice?

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When you become a client, you benefit from Xcina Consulting’s extensive subject matter expertise. We implement leading practices gained from assisting organisations across financial services sectors with their SM&CR requirements.

Our SM&CR compliance specialists have many years of practical experience on the subject across a range of firm types. They are also at the forefront of the latest developments, regularly conducting industry surveys, providing thought leadership and speaking at industry conferences on the topic.

Our team includes a blend of former Senior Managers, Heads of Compliance and Regulators. They provide pragmatic, value-adding solutions tailored to your specific context, not generic impractical recommendations.

We share our experience with you and provide knowledge transfer as required. With our training, your team will be equipped to use and maintain your SM&CR framework independently going forward.

Access subject matter expertise and advice upon request with our cost-effective solution.

What is The SM&CR?

The Senior Managers & Certification Regime (SM&CR) is a regulation in the UK financial services industry aimed at improving accountability and conduct within firms. It has two main parts:

Senior Managers Regime (SMR): This applies to senior individuals in financial firms, ensuring they are approved and certified for their positions. They are assigned clear responsibilities and held personally accountable for their area’s activities.
Certification Regime: This applies to most other staff in financial services firms. They must be certified by their employer as fit and proper to perform their role.

Here are some of the benefits of SM&CR:

Increased accountability: By clearly defining responsibilities and requiring approval for senior positions, SM&CR makes it easier to hold individuals accountable for their actions.
Improved conduct: The regime encourages staff to take more personal responsibility for their conduct and uphold high standards.
Clearer responsibilities: By assigning specific responsibilities to senior managers, SM&CR helps to avoid ambiguity and ensure everyone knows who is accountable for what.
Stronger market integrity: By improving conduct and accountability, SM&CR helps to create a more trustworthy and stable financial market.

A consultant addresses a client in a bright office.

Receive Independent Assurance on SM&CR Compliance

Our regulatory compliance consultants at Xcina collaborate with firms to deliver SM&CR advice and achieve the following:

An unbiased review (or support) using specialist external resources. We will assure the Board and Senior Management that relevant SM&CR policies, procedures and documentation are in place. We will ensure they are operating effectively to mitigate the risk of non-compliance with SM&CR requirements.
Providing peace of mind to individual Senior Managers. We will enable them to demonstrate compliance with Senior Manager Conduct Rules and to evidence the discharge of Senior Manager prescribed responsibilities – thereby mitigating individual accountability risk. These may relate to the Senior Manager Regime Certification Regime, Conduct Rules, and overall and other responsibilities.
Strengthening and further embedding of the SM&CR framework including Conduct Rules. We help you to sustain governance, accountability and a positive culture.
Regular sharing of insights into relevant regulatory trends and developments, as well as leading practices.

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Senior Managers & Certification Regime (SM&CR) Brochure

What our clients say

Lindsey and Xcina have assisted us with bespoke SMCR training and reviewed associated documentation. They have also assisted with various ad hoc compliance review requests. We have always found Lindsey to be very helpful and informed on the relevant subject matter. He has always been quick to respond to our requests and has been a pleasure to work with.

Chris Sloan, Director ClucasGray Investment Management UK Limited

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