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Certification – The Senior Managers & Certification Regime has started but there is still work to do…

  • United Kingdom
  • Consulting
  • Employment law
  • Financial services and markets regulation
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  • Financial institutions


The 7th March 2016 saw the start of the new Senior Managers and Certification Regime (SM&CR). To date, the majority of impacted firms’ focus may have been on mapping roles and the allocation of responsibilities to the new Senior Management Functions, as well as the drawing up of Responsibilities Maps and meeting the grandfathering requirements.

The 7th March also saw the launch of another of the key parts of the SM&CR, the Certification Regime. Firms now have until the 7th March 2017 to ensure those individuals subject to the Certification Regime are assessed as fit and proper and issued with a valid certificate for their role.

Eversheds has worked with a number of banks, building societies and insurance firms assisting and providing assurance on their activity and progress in preparation for the SM&CR. Our multi-disciplinary team, including leading regulatory and employment lawyers and specialist financial services regulatory consultants, is able to provide expert advice, guidance and assurance on the changes required to meet the new requirements.

Given the importance of getting certification right first time, it may be prudent for firms to obtain external assurance at an early stage to ensure that their new processes and procedures are fit for purpose and delivering the right outcomes. After all the firm has become its own mini regulator! To assist firms, Eversheds has designed a high-level assurance review programme focused on providing firms with an experienced external overview on their implementation of the Certification Regime. This service is available at a fixed price and includes:

  • an appraisal of the process for identification of individuals subject to the Certification Regime
  • a review of a sample of fit and proper assessments undertaken to date
  • a review of the firm’s processes and certification outputs to date.

Eversheds can also provide assistance in a variety of other areas linked to the SM&CR including systems and controls reviews, handover policy reviews, reviews of committee terms of reference, role profile reviews, assistance with the application of the conduct rules and new processes as well as bespoke training.

For more information contact

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