Responsibility is one of the fundamental pillars of the new Senior Managers and Certification Regime. By replacing the Approved Persons Regime, SMCR moves focus on responsibility over to specific Senior Managers within a firm.
As part of the process to approve any FCA regulated firm’s Senior Managers to the new regulation, a ‘Statement of Responsibilities’ must be submitted by a firm, and approved by the FCA for each of their Senior Managers.
When applying for a Senior Manager to be approved – all firms must submit a statement of responsibilities to the FCA.
Here are 10 practical tips for you to consider when writing a ‘Statement of Responsibilities’ for Senior Managers:
1. Stick to the facts, as it’s easy to become personable when describing your role.
2. Relevant prescribed responsibilities need to be listed in a Statement of Responsibility.
3. A clear explanation of any shared prescribed responsibilities need to be listed.
4. A Statement of Responsibility needs to be submitted for Core, Enhanced and Limited Scope firms.
5. The Statement of Responsibility must be kept up-to-date at all times, making the FCA aware of any changes by re-submitting the SoR. The FCA handbook states; “since the granting of the application, there has been any significant change in the aspects of the firm’s affairs which the FCA-approved SMF manager is responsible for managing in performing the function.”
6. A Statement of Responsibility is not expected to exceed 300-words.
7. Should be practical and useable by regulators.
8. Should Include clear descriptions of each responsibility, and not cluster responsibilities in the wording.
9. Avoid unnecessary detail. Keep to the facts, 300 words won’t last forever, make sure that the key details are all listed, and the jargon is not.
10. A Statement of Responsibility for a partner who’s day to day activities within a firm as limited, but is still considered a Senior Manager, is likely to be short. Make sure that as above, unnecessary detail isn’t given just to make up the 300 words. It is expected by the FCA that a SoR for a partner will be shorter.
Are you a Senior Manager who will have a Statement of Responsibilities attached to your name? If so, Arctick can offer to help you evidence reasonable steps to ensure you are SMCR compliant.
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