Accountability 2 is Coming!

We’ve recently returned from The Extension of the Senior Managers and Certification Regime conference run by City & Financial and held at the Royal Garden Hotel, London.

The conference was excellent and extremely busy with more than 250 delegates from across numerous sectors of financial services in attendance. Clearly, people are eager to find out more about the extension of SMCR and how it will affect their firms in 2018.

The agenda was certainly packed with one of the highlights being David Blunt’s keynote speech to kick things off. David is the Head of Conduct Specialists at the FCA and he provided some insights into when and how the regime will be extended.

  • The FCA have been running a pre-consultation process and this will continue into 2017 as they get out and about meeting firms and trade associations. The consultation paper will be issued in Q2 this year.

  • Implementation of the extended regime (referred to by David as ‘Accountability 2’ during his speech) will be ‘from’ 2018 and is likely to be phased by type of firm.

  • When SMCR came in for banking in 2016 it applied to approximately 1,000 firms, but with the extension across all FSMA firms, this will grow to 52,000. This is not the sort of thing that can be rolled out ‘over a weekend’.

  • Ultimately, it is The Treasury who will decide on the actual dates for implementation.

  • There are steps firms could be taking now to get ready, for example, conducting a self-assessment of their governance arrangements.

  • Insurers will be subject to SMCR, with the FCA being very keen to avoid having many different regimes for different sectors.

  • The guiding principles of ‘Accountability 2’ will be clarity, simplicity, consistency and proportionality.

Clearly, there’s a lot more detail to come and we’re all very eager to see the first consultation papers published later this year. That doesn’t mean you need to wait until then to kick things off, take a look at our SM&CR – Are you Ready? post to see what you can be doing now to get ready for the regime.