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Are you familiar with the SM&CR implementation periods for solo-regulated firms?

July 3, 2020

What has happened?

The deadline for solo-regulated firms to undertake the first assessment of the fitness and propriety of their Certified Persons and to undertake certain other tasks has been delayed from 9 December 2020 until 31 March 2021, since the FCA intends to consult on extending the deadline for the following requirements to 31 March 2021:

    • the date the Conduct Rules come into force for staff not classified as Senior Managers or Certified Persons
    • the deadline for submission, via Connect, of information about Directory Persons to the Register, which includes the Directory
    • the deadline for assessing Certified Persons as fit and proper

What do you need to do?

Senior Managers must ensure that Conduct Rules training is effective, so that staff are aware of the Conduct Rules and understand how they apply to them in their jobs. These programmes will require planning, time and effort to deliver effectively and a “tick box” or standardised e-learning approach will not be good enough. The FCA plans to produce further communications about its expectations in this area.

Firms should continue with their programmes of work in these areas and, if they are able to certify staff earlier than March 2021, they should do so. Firms should not wait to remove staff who are not fit and proper from certified roles.

The FCA will still publish details of certified employees of solo-regulated firms starting from 9 December 2020 on the Directory within the Financial Services Register. Where firms are able to provide this information before March 2021, they are being encouraged to do so.

How can we help you?

If you’d like to know more about how we can help with your SM&CR, certification and training processes, or any other aspect of FCA compliance, our expert team is here to help. Contact us today on 0207 436 0630 – or email