SMF Handover Policy

Posted on by Catherine Roberts

SMF Handover PolicyAn SMF Handover Policy is a mandatory requirement under the Senior Managers Regime. SYSC 25.9.4 of the FCA Handbook provides further guidance and rules for  Enhanced firms where an employee is performing a Senior Management Function (SMF). Reasonable steps must be taken to ensure they are provided with adequate information and the materials to carry out their duties effectively.

Subsequently, the handbook refers to a SMF Handover Policy as the key document in detailing the systems and controls in place for those starting or taking over and SMF function. The handover measures must comply with SYSC 25.9.4R and ensure that each person performing the role has suitable training and resources.

SMF Handover Guidance

  • The information and materials should contain information about: –
    • any unresolved or possible breaches of the requirements of the regulatory system.
    • any unresolved concerns expressed by the FCA, the PRA or another regulatory body.
  • The information be should: –
    • be aimed at helping the SMF Manager with their new or revised responsibilities and duties.
    • be practical and helpful information with specific guidance and examples (i.e. not just a record).
    • include an assessment of what issues should be prioritised.
    • include judgement and opinion from the existing SMF Manager (i.e. not just contain facts and figures).
  • There should be an time and resources allocated to ensure that there is an orderly transition.
  • The SMF predecessor should contribute to the information and materials, including any content that is based upon their opinion and is considered relevant.
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Catherine Roberts

Catherine Roberts is the founder and Director at Know Your Compliance Limited. She has worked in regulatory compliance and policy development for over 20 years, with first-hand experience in the financial services and consumer credit markets. Catherine is passionate about making compliance easier for businesses, developing templates and tools to simplify the process. When not tied to her computer writing policies, she enjoys reading, writing and graphic design.