Statement of Responsibilities: Drafting Tips for New SMFs
The Statement of Responsibilities is the document that defines what you are personally accountable for as a Senior Manager. Done well, it protects you and the firm. Done poorly, it creates ambiguity that the FCA will exploit if something goes wrong. Every proposed SMF holder …
Annual Certification: Practical Steps for Certified Persons
Annual certification is a genuine compliance obligation — not a bureaucratic formality. Firms that treat it as a tick-box exercise, and individuals who wait passively for their employer to manage it for them, both regularly find themselves in difficulty when the FCA asks questions. Under …
Senior manager handover: best practice when SMFs leave
Senior manager handover: best practice when SMFs leave When a Senior Manager leaves an FCA-regulated firm, the event triggers a series of regulatory and governance obligations that go significantly beyond a standard employment notice period and handover. The departing senior manager must be withdrawn from …
SMF24 in growing firms: why the Chief Operations Function matters
SMF24 in growing firms: why the Chief Operations Function matters The SMF24 Chief Operations Function is one of the less prominent Senior Manager designations — less widely discussed than the SMF2 CFO function or the SMF16 compliance oversight role, and less specifically defined in the …
Allocating Prescribed Responsibilities by Firm Type
Allocation of Prescribed Responsibilities: practical examples by firm type Prescribed Responsibilities are specific regulatory obligations that the FCA requires to be allocated to a named Senior Manager in every FCA-regulated firm. Unlike the Senior Manager Functions themselves — which define the areas a senior manager …
Career Paths to SMF16: Positioning for Compliance Oversight Roles
Career paths to SMF16: how to position for Compliance Oversight roles The SMF16 Compliance Oversight Function is one of the most technically demanding senior manager designations in the FCA’s SMCR framework. The individual holding SMF16 is personally accountable to the FCA for the adequacy of …
SMF2 vs CFO: when the FCA function differs from the corporate title
SMF2 vs CFO: when the FCA function differs from the corporate title The SMF2 Senior Manager Function designates the individual who has overall responsibility for a firm’s financial resources and financial reporting to the FCA. In most FCA-regulated firms, the SMF2 is held by whoever …
How to choose a skilled person: practical considerations under Section 166
How to choose a skilled person: practical considerations under Section 166 When the FCA requires a firm to commission a Section 166 skilled person review, the firm nominates the skilled person subject to the FCA’s approval. In practice, the firm has meaningful influence over who …
Surviving a Section 166 review: a CFO/COO action plan
Surviving a Section 166 review: a CFO/COO action plan A Section 166 skilled person review is one of the most significant regulatory interventions an FCA-regulated firm can face. Unlike a routine supervisory visit or a request for information, a Section 166 review under the Financial …
ICT incident reporting under DORA: timelines and templates
ICT incident reporting under DORA: timelines and templates DORA’s ICT incident reporting regime is one of the most operationally demanding aspects of the regulation for in-scope firms. Unlike the existing notification frameworks in most EU member states — which require prompt notification of significant events …
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