Conduct rules breach reporting: what the FCA expects from your firm
The Notification Obligation in Plain Terms Under the Senior Managers and Certification Regime, firms that have taken disciplinary action against an employee for a breach of the Conduct Rules must notify the FCA. This notification obligation sits within the FCA’s Supervision manual (SUP 15) and …
Conduct rules training: how to deliver something that actually changes behaviour
Why Most Conduct Rules Training Fails The FCA requires firms to train all Conduct Rules staff on the Individual Conduct Rules and to keep records evidencing that training has been delivered. Most firms meet this requirement. Very few meet it in a way that produces …
Hiring under SMCR: practical interview questions for senior manager candidates
Why Interviewing Under SMCR Is Different Recruiting a Senior Manager into an FCA-regulated firm is not simply a question of finding the most capable candidate. Under the Senior Managers and Certification Regime (SMCR), every appointment to a Senior Management Function (SMF) carries personal regulatory accountability …
SMCR Phase 1 Reform 2026: what the FCA’s policy statement actually changes
Why the FCA Is Reforming SMCR The Senior Managers and Certification Regime (SMCR) has been the framework for individual accountability in UK financial services since 2016 for banks and 2019 for solo-regulated firms. After more than five years of full operation, HM Treasury commissioned a …
SMCR vs APR: what was lost when the Approved Persons Regime was retired
The Regime That SMCR Replaced For twenty years, the Approved Persons Regime (APR) was the FCA’s primary framework for holding individuals at regulated firms to account. Introduced under the Financial Services and Markets Act 2000, the APR required firms to obtain FCA approval for anyone …
SMCR for Limited Scope firms: what changes if you’re a Limited Scope firm
What Is a Limited Scope Firm Under SMCR? When the Senior Managers and Certification Regime (SMCR) was extended to solo-regulated firms in December 2019, the FCA recognised that a single framework applied uniformly to every authorised firm would be disproportionate. The result was a three-tier …
Distribution Chain Obligations Under Consumer Duty: Who Does What
Distribution Chain Obligations Under Consumer Duty: Who Does What Manufacturer and Distributor Responsibilities, Information Flow, and Recruitment Implications For UK financial services products that pass through distribution chains — funds distributed through platforms and advisers, insurance products distributed through brokers, mortgage products distributed through brokers, …
Fair Value Assessments Under Consumer Duty: A Practical Framework
Methodology, Data Inputs, and the Substantive Analytical Standard the FCA Expects Fair value assessment is the most operationally demanding component of the Price and Value outcome under Consumer Duty, and the area where the gap between strong and weak firm practice has widened most visibly …
The Consumer Duty Annual Board Report: What Good Looks Like in 2026
The Consumer Duty Annual Board Report: What Good Looks Like in 2026 From First-Cycle Documentary Compliance to Substantive Outcome Evidence The Consumer Duty annual board report is now in its third cycle for most UK regulated firms. The first cycle (July 2024) saw firms producing …
How Consumer Duty Has Reshaped the SMF16 Compliance Oversight Role
From Conduct Compliance Manager to Substantive Customer Outcomes Owner The 2023 introduction of Consumer Duty under PS22/9 has done more than tighten conduct expectations — it has structurally reshaped what the SMF16 Compliance Oversight role actually involves day-to-day. Where the role historically combined conduct rule …
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