SM&CR Stocktake

The Senior Managers and Certification Regime (SM&CR) replaced the Approved Persons Regime (APR) for banks, building societies, credit unions and dual-regulated investment firms in March 2016. The SM&CR was created by legislation, based on the recommendations of the Parliamentary Commission on Banking Standards (PCBS). In 2017, we conducted a stocktake of the implementation of SM&CR in the banking sector. This was relatively light and relied on information available internally. The results were generally positive but it was recognised at the time that it was still relatively soon after implementation, with the last deadlines having only recently been passed. There has now been sufficient time for the regime to embed in firms and for any initial issues to have been overcome. We now want to undertake a further stocktake that will seek to provide more insight into how well the regime works in the banking sector. This will give the FCA the ability to consider corrective action if needed, give messages back to the industry and help guide the implementation of the SM&CR for other firms. The proposed work aims to assess the success of the SM&CR in the banking sector (including banks, building societies and dual-regulated investment firms). It will focus on the embedding of the regime in the industry.