Senior Manager & Certification Regime (SMCR) for Claims Management Companies

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Since Dec 9, 2019 it applies to all CMCs established or serving customers in or constituted under the laws of England and Wales or Scotland, including those who deal with Section 75 claims under the Consumer Credit Act 1974 (CCA) and trade bodies representing CMCs. It will be applied to all other CMCs (operating under the temporary permission regime) as soon as you are authorised.

  • The timeline of misconduct
  • The approved person regime
  • APER
  • SMCR framework
  • Senior Manager Functions (SMFs)
  • Statement of responsibility (SORs)
  • Duty of responsibilities
  • SMF conduct rules
  • FCA reasonable steps
  • Certification regime
  • Significant harm functions
  • The FCA register
  • F&P assessment
  • Certificate issuance
  • Conduct rules
  • Compliance with conduct rules
  • Breach reporting
  • Culpability standard
  • Regulatory reference
  • Next steps


Delivery options

  • Classroom session (3 hours)
  • Virtual classroom (3-hour webinar)
  • eLearning (design upon request)
  • In-house

Option 1: classroom

You attend alongside other market participants: £495

Option 2: virtual classroom

You attend alongside other market participants via an interactive online classroom: £395

Option 3: In-house

This course can be tailored specifically for your organisation and delivered at your offices, offering a cost effective solution for more than 5 employees.

  • Originally rolled out to the banking sector in 2016, the Senior Managers and Certification Regime (SMCR) was extended to all regulated firms (~47,000) in December 2019. Learn about SMCR; what it is, what it means and why it matters
  • This regime affects all FCA regulated firms including non-UK firms with permission to carry out regulated activities in the UK, the workshop focuses on three key areas:
    • The Senior Managers Regime
    • The Certification Regime
    • Conduct Rules
  • Firms are required, by FSMA 64B, to train relevant staff on how Conduct Rules apply to their role and a Senior Manager is required to be allocated the prescribed responsibility (PR) for this
  • Failure to adhere to the conduct rules creates an obligation for regulated firms to report to the FCA
  • Senior Managers who fall under the SMF categorsiation and need to ensure they are fully aligned to their obligations as part of SMCR
  • Significant harm functions employees (aka certified persons) who are now subject to SMCR conduct rules but may yet to be certified as competent by their organisation
  • Professionals in support functions for SMCR such as HR, Compliance, Legal and Technology who require a front-to-back overview

Our SMCR for Claims Management Companies Course covers;

  • Overview and journey to the SMCR regime
    • The backstory to SMCR; the Parliamentary Commission for Banking Standards (PCBS)
    • The regulatory reaction
    • The Fair & Effective Markets Review
    • The road to Implementation
    • Aims and Objectives of SMCR
    • What is the SMCR, what does it mean and why does it matter
  • Key Regime Features
    • The enhanced regime
    • The core regime
    • The limited scope regime
    • Overview of new staff categorisations
  • Senior Managers Regime
    • SMF categories
    • Statement of responsibilities
    • Management responsibility maps
    • Duty of responsibility
    • Reasonable steps
    • Exercise – define reasonable steps in the context of the SMF rules; what the FCA guidance states and best practice
  • Certification Regime
    • Significant harm functions
    • Fitness and Competency checks
    • Annual assessments
    • Self-certification
    • Regulatory references
  • Conduct Rules
    • SMF Conduct rules
    • Individual conduct rules, what are they and how do they apply
    • Exercise – define and identify potential breaches and evidence on how to adhere to the rules
    • Class quiz – which rule was broken
    • Case Study – Jes Staley, CEO Barclays
  • Breach Reporting
    • The link between disciplinary issues and conduct rule breaches
    • Breach reporting obligations to the FCA
  • This SMCR for Claims Management Companies Course provides a holistic overview of SMCR, allowing participants to conduct a current state analysis of their SMCR roll out  
  • Leverage the trainer’s extensive experience with the banking rollout we look to unpick the lessons to be learned for the SMCR extension to all regulated firms
  • Packed with practical exercises to focus on the identification of key employees and what you need to do to be on-track with SMCR

Matt Fotherby

Financial Markets, Compliance & Regulations

Matt is our Founder and a passionate trainer.

His interest in education stems from his 10 years as an Account Executive looking after Global Hedge Fund and Asset Management clients. Matt quickly discovered that many of the financial market topics that his clients wanted to learn about were the exact same topics that he was striving to develop a better understanding of himself.

This led Matt to join the coveted Financial Markets Education team at UBS, a unique in-house education team that specialised in running a curriculum of financial market and product classes for both UBS employees and clients. Matt was responsible for building out the client offering; managing programs, creating content and teaching courses.

As financial markets entered a significant period of regulatory change Matt pivoted to take his client experience and market knowledge to focus on Regulations and Compliance topics.

Matt leverages his time spent as an attendee of training and fuses this with his deep markets knowledge and regulatory expertise to deliver engaging training designed to decipher complexity and equip learners with the knowledge they need to remain compliant and competent within their roles.

Matt leads on our Compliance & Regulations offerings.

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