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Senior Managers Regime (SMCR) Explained

Senior Managers & Certification Regime (SMCR) – A Practical Guide & Workshop

A ½ Day Course

Join our half-day workshop to learn about the FCA’s Senior Managers Regime, [Senior Managers & Certification Regime SMCR] and its key features like who does the certification regime apply to, Conduct Rules, and more..

What Makes This Course Different?

  • Need a kick start to your SMCR project? well this workshop will equip you with everything you need to know and everything you need to do
  • Leveraging the trainers experience with the banking rollout we look to unpick the lessons to be learnt for the SMCR extension to all regulated firms
  • Packed with practical exercises to focus on the identification of key employees and what you need to do in the lead in to SMCR
  • Conduct rules; what are they, what do they mean & why do they matter?
  • Walk away with a clear plan of your next steps for your SMCR implementation



  • Review and understand the backstory to SMCR and where it came from
  • To know and understand the key employee categorisations within your firm, SMFs, CP, non-approved and ancillary
  • Be able to evaluate your SMFs; who are they and what they need to know
  • Analyse your CPs and define who will be in this category
  • Apply the conduct rules to your firm and your organisation
  • Review the breach process and how to apply within your firm



Overview and journey to the SMCR regime – briefly!

  • The backstory to SMCR; the Parliamentary Commission for Banking Standards (PCBS)
  • The regulatory reaction
  • The Fair & Effective Markets Review
  • The road to Implementation
  • Aims and Objectives of SMCR
  • What is the SMCR, what does it mean and why does it matter

Key Regime Features

  • The enhanced regime
  • The core regime
  • The limited scope regime
  • Overview of new staff categorisations

Senior Managers Regime

  • SMF categories
  • Prescribed responsibilities
  • Statement of responsibilities
  • Management responsibility maps
  • Duty of responsibility
  • Reasonable steps


  • Map your own company statements of responsibility
  • Map your own responsibility map (Core & Limited)

Certification Regime

  • Significant harm functions
  • Fitness and Competency checks
  • Annual assessments
  • Self-certification
  • When to asses Fitness & Propriety
  • Regulatory references and why they need to be accurate

Conduct Rules

  • Individual conduct rules, what are they and how do they apply
  • Tier 2 Conduct rules for SMFs
  • Reasonable steps for SMFs

Breach Reporting

  • The link between disciplinary issues and conduct rule breaches
  • Breach reporting obligations to the FCA

What we can learn from Phase 1 of the banking roll out

  • What we can learn from banking experience to date
  • Transitioning to the SMCR
  • Taking Action


Background of the Trainer

Course Director
Lee has worked with a range of organisations from small start-ups through to FTSE100 companies, many that have had difficulties identifying and managing conflicts of interests, and helped them develop effective, robust systems. He has adapted his experience to develop this course and supporting materials with the practical skills-based focus. Lee’s skills, qualifications and experience make him ideal for supporting anyone wishing to develop top-class knowledge in the management of conflicts of interests.
Having been a freelance consultant and trainer for twenty years, your course director was appointed as a skilled person in 2012 and has conducted many audits, assessments, roll-outs and change management programmes from complaints programs, conduct risk frameworks, global risk frameworks, as well as having provided regulatory interpretation to investment banks, worked on many risk mitigation programs and set up banks.

Course Summary

Originally rolled out to the banking sector in 2016, the Senior Managers and Certification Regime (SMCR) is about to be extended to around 47,000 additional firms.
Beginning with insurance companies, from December 2018, and reaching asset managers and other regulated firms in December 2019.
The Financial Conduct Authority (FCA) is tightening up its rules, replacing the current Approved Persons Regime with the Senior Managers and Certification Regime (SMCR). The regime has already been operating in the banking sector for some time and will this year extend to all within the financial services sector.
This change will affect all FCA regulated firms including non-UK firms with permission to carry out regulated activities in the UK, and it will focus on three key areas:

  1. The Senior Managers Regime
  2. The Certification Regime
  3. Conduct Rules

Target group

  • All staff within authorised firms will be in scope
  • Senior Manager Functions (SMFs)
  • Certified Persons (CPs)
  • Non-approved
  • Also strongly recommended for those who will be directly involved in the implementation; Compliance & HR.


Duration is as a half day classroom workshop

Call us on 0207 097 1434


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