SMCR Policy Template Toolkit

Our SMCR Template Toolkit provides detailed content about the Senior Managers and Certification Regime (SM&CR). It is written in the first person, making it easy to corporate brand and implement into your organisation. Furthermore, we provide the FCA guidance in this area in bullet point, concise content. The FCA rules have been used to develop the content, ensuring compliant, high-quality policies and templates.

Our SMCR Toolkit includes 4 unqiue skills gap analysis tools and templates. Start by reading through our policy content to understand the SMCR and FCA requirements in this mandatory area. Next, complete the provided skills gap analysis for each employee performing a key business function. Lastly, our skills tools and templates will assist you in identifying, analysing and reviewing the desired skills as applicable to your business type. The skills gap analysis suite includes: –

• Skills Gap Analysis Procedure
• Employee Skills Gap Analysis Assessment Form
• Group Skills Gap Analysis Assessment Form
• Skills Gap Analysis Tool (Excel)

A Statement of Responsibilities (SoR) is a mandatory document required for each Senior Manager, setting out their role, obligations and responsibilities. Furthermore, this document is a requirement under the FSMA. Therefore, the FCA already offer a detailed and compliant template for the SoR. We have consequently included their version in our pack as this is clearly the best version of this template for use. The SoR is not part of the pricing of this pack and can also be downloaded for free form the FCA’s website.

SYSC 25 of the FCA Handbook states that firms should have a Management Responsibilities Map to help them and the FCA satisfy themselves that there is a clear organisational structure. SYSC 25 also defines what should be included in the map, for which we have provided a detailed template with all mandatory areas to save you time and resources.

Fit and proper assessment covers certification staff as well as Senior Managers. Therefore, it is essential that you have effective tools and controls for assessing and evidencing a person’s fitness and propriety. Our SMCR Template Toolkit includes detailed assessment records and an assessment template for the criteria to be assessed and documented.

Enhanced firms are required to take reasonable steps to ensure that any person taking over a Senior Manager role has all the information and materials they need to perform the role. Handover documents should be developed for all Senior Manager functions by the person currently performing the role, to ensure that effective handovers are possible. The FCA advise that “firms must have a policy which explains how it complies with this requirement”. We have included a SMF Handover Policy in the SMCR Toolkit which details how you should draft the handover document and what steps your firms takes to comply with this requirement.

This Excel based register is a simple template that enables firms to keep a record of their Senior Managers, their responsibilites and the functions that they perform.

Our SMCR Checklist provides a tool for assessing compliance with the SMCR rules. Through self-assessment questions, the checklist verifies if controls are adequate, effective and compliant. Once complete, the checklist provides information on any gaps in the SMCR processes and can evdence if relevant employees are suitable and certified.

An individual appointed to an SMF function must be assessed for role suitability. This includes due diligence and background checks as well as experience and qualifications. SMF due diligence also applies to anyone performing Certification Functions (CF) that have a significant effect or impact on the customer, firm and/or market integrity. Our SMF due diligence questionnaire gives you the tools for performing assessments and verification on employees.

Use our SMF Induction Checklist for new starters within the business if they have been appointed specifically to undertake an SMF role. It can also be used for existing employees who have been promoted or moved into a SMF/CF role. The checklist assesses your SMF processes and validates them against the requirments,. It also provides you with a tool for reviewing the adequacy of the candidate and role effectiveness.

Covering both tiers of Conduct Rules (Individual & Senior Manager), our Conduct Rules Policy provides objectives for conduct rules compliance. The policy also covers how to develop adequate training for employees and effective processes for conduct rule breach reporting.

It is part of a firms fitness and propriety responsibilities to train all relevant employees on the Conduct Rules. In addition to the training sessions, the firm must be able to evidence that the training has taken place. Training content must be suitable and geared towards the role being performed. This may mean developing several SMCR training programs to ensure the content is relatable to each employee and specific functions. Most firms develop their own training sessions as this area is bespoke to each business type. However, we have included an extensive guidance document covering how to develop effective SMCR training. This includes the SMCR areas to cover; how to format the training and examples of each conduct rule.

Our toolkit contains a certificate template for use with employees who are performing a certification function role. Section 63F of the Act (and SYSC 27.2.9 G in FCA Handbook) states that a certificate issued by a firm to a person must comply with the below.

1. It must state that the firm is satisfied that the person is fit and proper to perform the function to which the certificate relates; and
2. sets out the aspects of the affairs of the firm in which the person will be involved in performing the function.

There are 3 types of SMCR Firm, limited, core and lastly, enhanced. Each of these types have different Senior Management Functions and Prescribed Responsibilities. Our SMCR toolkit contains simple guidance to help you understand which firm type you are. In addition, the guidance provided details which SMFs and PRs apply to each.

Training & Development Policy covering induction, ongoing and Conduct Rules training for employees. We have also provided templates for training evaluation, training feedback and training and development logs.

It is important that employees are aware of their obligations under the SMCR. Therefore, employees reporting or disclosing information about breaches must be supported and protected. Our toolkit contains a customisable Whistleblowing Policy to cover legislation under the FCA and PIDA.

Under the SMCR requirements, the FCA can request to see a firms policies and controls for recruitment, selection and induction. We have now added the below documents to our SMCR pack to help firms comply in this area.

• Induction Policy & Checklist.
• Recruitment & Selection Policy.
• Job Description Template.
• Sample Interview Questions.