The SM&CR Case Study Series: Issue 4 - Fitness and Propriety of Senior Managers
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About our SM&CR case study series
This is the fourth instalment in our SM&CR case study series, designed to help you prepare for the implementation of the FCA’s Senior Managers & Certification Regime (SM&CR). This series follows fictitious firm Smith & Cromer Limited’s project to implement the Regime with the process and tips being released to you throughout the year.
Have you:
- Read the first three instalments?
- Watched our one-minute explainer video – SM&CR in a Nutshell?
If you are up to date, read on...
About our case study firm
Remember Smith & Cromer Limited is a fictional solo-regulated firm active in the wholesale markets with 25 staff in total, including 20 approved persons. There are five executive directors and two non-executives; one of whom performs the role of Chair at the firm. All but one of the executive directors also performs the customer function under the Approved Persons Regime. The compliance function and the MLRO function are both performed by Sam Carr, who is not a director of the firm.
Sam is steering the SM&CR project plan and, so far Smith & Cromer has identified the senior managers and certification staff, and considered the documentation updates that will be necessary for the SM&CR to be implemented in the firm. It is now time to assess the fitness and propriety of the senior managers fulfilling SMFs, and devise training plans to address any shortcomings.
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The Senior Managers and their prescribed responsibilities
The individuals who will take on the senior management functions (SMFs) for Smith & Cromer under the SM&CR have been identified as follows:
The SM&CR’s prescribed responsibilities for Smith & Cromer have also been allocated and included in the relevant Senior Managers’ Statements of Responsibilities (SoRs) that will be formally applicable at the start of the Regime.
Read this instalment of our SM&CR case study series to see Sam's next steps and key takeaways from this stage in the SM&CR Implementation Plan...
