FCA publishes final rules on the extension of the Senior Managers and Certification Regime

The Financial Conduct Authority (FCA) has today published its final rules on the extension of the Senior Managers and Certification Regime (SMCR) to the majority of FCA solo-regulated firms. In general, the FCA has implemented the proposed changes to the SMCR as consulted on. The main changes to the FCA's existing rules include:

• confirming that the Head of Legal function is not required in Senior Managers Regime;
• amending the intermediary revenue criterion for the Enhanced regime;
• clarifying the requirements and scope of the Certification Regime (in particular, the scope of the Client Dealing Function and the application of the Systems and Controls roles); and
• extending Senior Manager Conduct Rule 4 (SC4) to non-approved Executive Directors at Limited Scope firms.

Firms now have until 9 December 2019 to implement the final rules, although certain rules will be phased-in over time, and ensure that they are compliant with the new regime.