Extension of SM&CR implementation for solo regulated firms

18 November 2020

The FCA has announced the deadline for solo-regulated firms to have undertaken the first assessment of the fitness and propriety of their Certified Persons has been delayed from 9th December 2020 until 31st March 2021.

To ensure SM&CR deadlines remain consistent and to provide extra time for firms that need it, the FCA has consulted on extending the deadline for the following requirements from 9th December 2020 to 31st March 2021:

  • The date the Conduct Rules come into force
  • The deadline for submission of information about Directory Persons to the Register
  • References in our rules to the deadline for assessing Certified Persons as fit and proper (which has been agreed by the Treasury) 

The final policy statement is now awaited.

What should brokers do?

Firms should continue to make sure that they are able to certify staff earlier than the March 2021 deadline if this is feasible. They should not wait to remove staff who are not fit and proper from certified roles. 

The FCA is consulting alongside the parliamentary process to give regulated firms certainty and to finalise a policy as soon as possible.

Compass’ advice

Senior Managers must ensure that effective Conduct Rules training is undertaken and completed on time, so that staff are aware how they apply to their role.

When it is feasible to do so, a nominated person should undertake the first assessment of the fitness and propriety of your Certified Persons. 

If you have any questions or concerns, please don’t hesitate to speak to your BDM.

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