The FCA state “The SM&CR is a catalyst for driving cultural transformation and sets a new standard of personal conduct in financial services. By 9 December 2020 solo-regulated firms will need to ensure:
- all relevant staff are trained on the 5 Conduct Rules and understand how these rules apply to their roles
- all staff in certified roles are fit and proper to perform that role and are issued with a certificate
- you submit data to us (via the Connect system using the new directory persons Connect form ) for directory persons working in financial services”
‘Directory persons’ includes;
-All Certified staff (those holding a certification function under the Senior Managers and Certification Regime (SM&CR))
-Directors who are not performing Senior Manager Functions (SMFs) – both executive and non-executive
The form basically requires you to log – Name, Job Title, Role Performed.
Sector Views
The FCA have now published their latest Sector Views analysis of the risks and harm they see across financial services markets. It sets out their comprehensive assessment of the state of financial services markets, the key concerns they are already working on and the problems that they are planning to address. Consumer Credit is shown in Chapter 3 and their main focus of concern is HCSTC, Peer To Peer lending (P2P), and poor value from Claims Management Companies. (CMCs)