With a little over a month to go before the Senior Managers & Certification Regime comes in, use the questionnaire below to find out what you need to be doing in order to get ready in time. 

The following is an overview of what you need to do for the SM&CR; this does not take into account any changes to approved persons within the business.  If you are planning on changing the current individuals in the business or take on additional approved persons then the appropriate notification applications need to be submitted to the FCA.  Additional checks are then required such as regulatory references and DBS check on new senior managers.  If you are unsure on what you need and need support please get in touch.  

1. Are you a sole trader?

Yes - go to question 2

No – go to question 5

2. Do you have advisers and/or finance admin staff

Yes – go to question 3

No – go to question 4

3. You are a sole trader with staff other than ancillary staff you will be classed as a limited scope firm and need to do the following:

 - Put in place appropriate SMCR procedures for the firm

- Complete a Limited scope statement of responsibilities

- All senior managers and certification staff (advisers) need to ensure they are fit and proper; this assessment will include following your firms T&C procedures for on-going competency as well as any standard checks made on advisers such as credit searches, completing a fitness questionnaire, financial soundness

- Conduct rules training for all senior managers, advisers and finance admin staff (anyone other than ancillary staff)

- If applicable update your employment T&Cs, disciplinary and referencing process

- Report information about Directory Persons for certification staff and sole trader

- Issue a certificate to certification staff (advisers) confirming they are fit and proper

For template SMCR documents click here

4. You are a sole trader with either no staff or ancillary staff only; you are classed as a limited scope firm and need to do the following:

SMCR wont apply to some sole traders with no employees if they wont hold a SMF   

- Put in place appropriate SMCR procedures for the firm

- Complete a Limited scope statement of responsibilities

- As the senior manager you need to ensure you can evidence you are fit and proper; this assessment will include following your firms T&C procedures for on-going, completing a fitness questionnaire, financial soundness

- Conduct rules training, understanding how the conduct rules apply to your role

- If applicable update your employment T&Cs, disciplinary and referencing process

- You may need to report information about yourself to the FCA Directory

For template SMCR documents click here

5. Do you have advisers and/or finance admin staff

Yes – go to question 6

No - go to question 7

6. You are a partnership or limited company with staff other than ancillary staff and classed as a core firm and need to do the following:

- Put in place appropriate SMCR procedures for the firm

- Complete a Core firm statement of responsibilities for all senior managers, with clear prescribed responsibilities assigned to the relevant manager

- All senior managers and certification staff (advisers) need to ensure they are fit and proper; this  assessment will include following your firms T&C procedures for on-going competency as well as any standard checks made on advisers such as credit searches, completing a fitness questionnaire, financial soundness

- Conduct rules training for all senior managers, advisers and finance admin staff (anyone other than ancillary staff)

- If applicable update your employment T&Cs, disciplinary and referencing process

- Report information about Directory Persons for certification staff

- Issue a certificate to certification staff (advisers) confirming they are fit and proper

For template SMCR documents click here

7. You are a partnership or limited company with either no staff or ancillary staff only and classed as a core firm and need to do the following:

- Put in place appropriate SMCR procedures for the firm

- Complete a Core firm statement of responsibilities for all senior managers, with clear prescribed responsibilities assigned to the relevant manager

- As the senior manager you need to ensure you can evidence you are fit and proper; this assessment will include following your firms T&C procedures for on-going, completing a fitness questionnaire, financial soundness

- Conduct rules training, understanding how the conduct rules apply to your role

- If applicable update your employment T&Cs, disciplinary and referencing process

For template SMCR documents click here

We have the template documents needed to be SM&CR compliant, please get in touch to find out more on what you need based on your firm type and size and how we can help.