FCA clarifies SM&CR responsibilities for firms in relation to COVID-19

Regulatory Updates | 26/03/20

The Financial Conduct Authority (FCA) has updated its webpage on its response to the COVID-19 pandemic to include a new section on responsibilities under the Senior Managers and Certification Regime (SM&CR). The FCA does not require that firms have a single senior manager responsible for its response to COVID-19, rather that responsibilities should be allocated in a way which best enables firms to manage the risks they face. The FCA notes that there are existing relevant responsibilities in the Senior Managers Regime, for example SMF24 for operational resilience, and SMF2 for financial resilience. Firms should also consider the FCA’s recommendation that the SMF1, or most relevant member of the senior management team, be responsible for their approach to identified key workers.