Today, the FCA has published a guidance consultation, "Senior Managers and Certification Regime: Proposed guidance on statements of responsibilities and responsibilities maps for FCA firms" (GC18/4).

The guidance aims to give practical assistance and information to firms preparing Statements of Responsibilities (SoRs) and Responsibilities Maps. It builds on the information published in the FCA Guide to the SM&CR for solo-regulated firms and is primarily for FCA solo-regulated firms, although the FCA indicates that it may also be of interest to firms regulated by the PRA and FCA, subject to the SM&CR.

The guidance:

  • sets out the purpose of SoRs and Responsibilities Maps;
  • directs to relevant Handbook references;
  • provides some questions for firms to ask themselves when preparing (i) SoRs, ordered by the relevant section on the "Statement of responsibilities for solo-regulated firms" form, and (ii) Responsibilities Maps;
  • gives example SoRs and Responsibilities Maps based on the case studies in the FCA's SM&CR: Guide for FCA solo-regulated firms; and
  • outlines examples of good practice (in green boxes) and poor practice (in burgundy boxes).

The FCA warns that questions and examples are not to be considered exhaustive, but the guidance provided may be applied in a risk-based and proportionate way.

Additional guidance from the FCA in this area is to be welcomed. Firms should consider the content and feedback to the FCA as appropriate. The consultation is open until 10 December 2018.