The Senior Managers and Certification Regime (SM&CR) is widening beyond banks and insurers to all firms authorised to provide financial services under the Financial Services and Markets Act. It will replace the existing Approved Persons Regime for these firms in late 2019.
As part of the SM&CR, the FCA introduced a new set of conduct rules that will apply to all employees within firms – not just approved individuals. These enforceable rules set basic standards of good personal conduct against which the regulator can hold people to account. The FCA views these conduct rules as a means to improve standards of individual behaviour in firms from the top down and the bottom up. The conduct rules are described as a meaningful change in the standards of conduct the regulator expects from those working in the industry.
- Introduction – application and logic of the SM&CR conduct rules
- FCA’s Code of Conduct (COCON)
- The two tiers of SM&CR conduct rules
- The five individual conduct rules
- The four senior manager conduct rules
- Exclusion of ancillary staff
- Activities to which the rules apply
- FCA guidance on the rules
- The notification and training requirement
- Breach reporting and the annual notification
- End of module assessment
Note – The FCA’s rules require firms to ensure employees understand the practical impact of the conduct rules in their own roles. As a result, we recommend that this module is supplemented by face-to-face training to ensure understanding of how the rules apply in the context of specific job roles.
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