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Published 29 May 2018
The Senior Managers and Certification Regime (SM&CR) aims to create a culture of accountability and responsibility within regulated firms and to act as a credible deterrent for misconduct. SM&CR already applies to UK banks.
In late 2017, the FCA and the PRA confirmed that SM&CR will be extended to insurers in late 2018 (with final rules and a commencement date expected to be announced in the summer). They also confirmed that SM&CR will not apply to solo-regulated firms (those regulated only by the FCA) until mid-to-late 2019.
Therefore, whilst SM&CR is likely to be an immediate priority for insurers, we expect many solo-regulated firms (particularly those that are not part of larger insurance groups) will not focus on it until later in the year.
Many insurers will already have implemented the Senior Insurance Managers Regime (SIMR), which is a half-way house to SM&CR. With that in mind, this article focuses on the steps that insurers will need to take to transition from SIMR to SM&CR.
We can help
We have a cross-practice team of employment lawyers, regulatory lawyers and corporate governance experts who have advised banks to implement SM&CR and insurers to implement SIMR. We are also assisting firms to transition from SIMR to SM&CR. If you would like to talk to us about your SM&CR project, please contact David Sims, Mathew Rutter, Giles Peel or Joanne Owers.
London - Walbrook
+44 (0)20 7894 6327
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