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Latest Articles

The SM&CR Case Study Series - SM&CR documentation updates

1st May 2019

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About our SM&CR case study series

This is the third 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:

  1. Read the first two instalments?
  2. 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. 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, after identifying the senior managers at the firm, those that need to be certified as fit and proper, and the remaining staff, it is now time to consider the documentation updates that will be necessary for the SM&CR to be implemented.

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SM&CR documentation updates

Documentation to be updated and drafted

Sam has carefully reviewed relevant guidance from the FCA’s website and, after discussion with Smith & Cromer’s retained compliance consultants, she has come up with three key areas to consider:

  1. Statements of Responsibilities
  2. Code of Conduct
  3. Responsibilities Map

Read the latest instalment of our SM&CR case study series to read how Sam approaches this stage of the SM&CR implementation plan...

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Additional

Useful resources

  • Ccl Acad Smcr Issue3 May19
    Ccl Acad Smcr Issue3 May19

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