FCA has noted the anniversary of the SMR taking effect, as the rules on regulatory references now come into force. Firms also had to have issued certificates for all staff who fall within the certification regime, and the Conduct Rules now apply to all staff except those in purely ancillary functions.
FCA is in principle pleased with what has happened in the past year, but acknowledges cultural change needs time to bed in. It has also noted some firms have not clearly allocated or understood senior manager responsibilities, so there is some evidence of overlapping or unclear allocations, or responsibilities that are shared in such a way it is hard to tell who is genuinely responsible.
FCA will now proceed with its planned consultation on extending the SMR to all firms in a clear, simple and proportionate way. The consultation is planned for mid-2016, with implementation “from” 2018.