This event is being organised in response to demand from the market following our successful summit on this subject in January and is being held shortly after the publication of the FCA’s consultation paper on how it will implement the extension of the SMCR.

We are particularly pleased that Jonathan Davidson, Director of Retail Supervision and Authorisation at the Financial Conduct Authority, has kindly agreed to give the opening keynote address.

The government is proposing to extend the Senior Managers and Certification (SM&CR) regime to all sectors of the financial services industry, replacing the discredited Approved Persons Regime. The FCA has announced that the extension will take place in early 2018. 

The key features of the extended SM&CR are:

• an approval regime focused on senior management, with requirements on firms to submit robust documentation on the scope of these individuals’ responsibilities 
• a statutory requirement for senior managers to take reasonable steps to prevent regulatory breaches in their areas of responsibility 
• a requirement on firms to certify as fit and proper any individual who performs a function that could cause significant harm to the firm or its customers, both on recruitment and annually thereafter 
• a power for the regulators to apply enforceable Rules of Conduct to any individual who can impact their respective statutory objectives 

The FCA has said that it will ensure that the extended regime appropriately reflects the diverse business models operating in the UK market and is proportionate to the size and complexity of firms. 

Given the fundamental changes that firms will need to make in advance of its implementation, it is widely acknowledged that they need to start preparing as soon as possible. 

The summit addresses the needs of c-suite executives in those institutions that are due to fall within the ambit of the extended regime, including investment firms, insurance companies and consumer credit firms. Currently, 10,500 individuals fall within the SMR and another 32,302 within the certification regime. The extension will potentially bring a further 92,300 individuals into the SMR and 66,000 into the certification regime for the first time.       

The  programme will tackle the key issues from a very practical perspective. The final programme will be structured around the proposals set out in the FCA’s recent paper, but is likely to cover the following elements:

• The FCA’s strategic approach to implementation of the extension of the SMCR
• How will proportionality work in practice?
• Senior Management Functions and allocating responsibilities under the extended SMCR
• What will be required in terms of statements of responsibility?
• Understanding the duty of responsibility and enforcement issues
• Whistle-blowing and the extended SMCR regime
• Impact of the extension of the SMCR on HR practices, reporting lines and organisational structure
• Best practice for individual senior managers under the extended SMCR
• Complying with the Certification regime – what will it mean in practice?
• Record-keeping under the extended SMCR
• Are there useful lessons to be learned from the introduction of the SMCR in the banking sector?  
• Scope for mitigating personal regulatory risk through insurance
• Practical checklist/guidance for firms implementing the requirements of the SMCR regime