Extension of SM&CR Implementation Period for Solo-Regulated Firms

The FCA and the Treasury announced yesterday that they have agreed to push back the deadline for FCA solo-regulated firms’ assessment of their Certified Staff as fit and proper to 31 March 2021, just over 100 days from the original deadline of 9 December 2020.

The FCA expects to finalise its consultation process shortly, which will ensure that any affected SM&CR deadlines are streamlined with this change.

The deadline for Directory submission is also being moved to 31 March 2021, but the details of certified staff that have been submitted by the earlier date will be published temporarily in the FS Register. Firms are encouraged to submit by the original deadline of 9 December 2020, if they can.

ACA Guidance

While this extension gives you a little more breathing space, the FCA expects you to continue with your programmes of work in the areas of certification, submission of information to the Directory and Conduct Rules training. Where feasible, the regulator would like the relevant actions to be concluded and completed ahead of the new deadline.

Here are some questions you can ask yourself to check the state of your compliance readiness: 

•    Have you reviewed your SM&CR implementation documentation and internal processes to make sure they meet regulatory expectations? 
•    Have you assessed whether the COVID-19 pandemic has an impact to your firm’s implementation of SM&CR? 
•    Have Senior Managers at your firm ensured that Conduct Rules training is effective, so that staff are aware of the rules and understand how they apply to them in their jobs?

How we help

Contact us or call +44 (0)20 7042 0500 to learn more about our comprehensive and practical suite of SM&CR solutions, designed to help firms and individuals review and maintain compliance against regulatory requirements and expectations. Our SM&CR services include post-implementation assurance reviews of your firm's current framework and ongoing assistance with employee assessments and training.