As the FCA prepares for the extension of SMCR to most solo-regulated firms next December, it is consulting on a few areas regarding the existing regime for banks and large insurers previously identified as wanting attention.
The proposals set out in CP19/4 include:
- excluding the legal function from the scope of SMCR;
- amend the scope of the Client Dealing Function in the Certification Regime to allow firms
to exclude purely administrative roles that involve ‘taking part in’ investment activities; and - ensuring that the Certification Regime applies to individuals performing roles that were Systems and Controls functions under the Approved Persons Regime, but which are no longer approved under SMCR.
The consultation closes on 23 April 2019.