SMCR Policy Template Toolkit

As we already provide FCA compliance policies, manuals and templates to thousands of regulated firms, we can ensure a winning formula with our SM&CR Document Pack. Priced at just £145 (exc vat) to ensure that in addition to larger firms, SME’s and sole traders can afford to implement the Senior Mangers and Certification Regime (SM&CR) which applied to solo-regulated firms from 9th December 2019. SMCR Toolkit


Whilst the SMCR rules and requirements were enforced from the 9th December 2019, solo-regulated firms were given an additional 12 months (later extended) to develop and implement certain areas of the SM&CR. Prior to the 31st March 2021, solo-regulated firms needed to ensure that: –

  • all relevant staff are trained on the Conduct Rules and how they apply to their roles
  • all staff in certified roles are assessed as fit and proper to perform that role and are issued with a certificate
  • they submit data to the FCA for the directory of key people working in financial services

Below is more information on what is included in the pack and how it can help you to develop a compliance SM&CR program within your organisation.

SM&CR Policy Document

Our SM&CR Document gives you detailed content about the Senior Managers and Certification Regime (SM&CR) and is written in the first person, making it simple to corporate brand and implement into your organisation. Covering much of the guidance provided by the FCA in the relevant publications and handbook, we have tied the content to the many templates and policies included in the pack. 

Statement of Responsibilities

A Statement of Responsibilities (SoR) is a mandatory document required for each Senior Manager, setting out their role, obligations and responsibilities. It is required under the FSMA and as the FCA already offer a detailed and compliant template for the SoR, we have included their version in our pack at no extra cost as we do not believe in charging for content that is freely available elsewhere.

Management Responsibilities Map Template

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 Assesment Record Template

Included in the extension of the SM&CR is the application of the fit and proper guidance in the FIT part of the FCA Handbook, which now covers Certification staff as well as Senior Managers. There are specific requirements and processes for assessing a person’s fitness and propriety, for which we have included a detailed assessment record which defines all the areas that a firm should assess and verify.

SMF Handover Policy

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.

SMF & PR Register Template

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.

SMF Due Diligence Checklist

Our SMCR Checklist enables firms to run through a series of questions to ensure that they have implemented adequate, effective and compliant SM&CR processes and that all relevant employees have been adequately assessed and certified.

SMF Due Diligence Questionnaire

People carrying out SMF functions are referred to as Senior Managers and it is essential that such employees or candidates meet the SM&CR regulations and requirements when being assessed and appointed (this includes those performing Certification Functions (CF) that have a significant effect or impact on the customer, firm and/or market integrity). Our SMF Due Diligence Questionnaire helps firms to evidence their checks and due diligence and to carry out the mandatory assessments and verification on employees performing (or being considered for) SMF/CR roles.

SMF Induction Checklist

Our unique SMF Induction Checklist is for both new starters within the company who have been appointed specifically to undertake such a role, and for existing employees promoted or moved into a SMF/CF role. The checklist helps firms to  ensure that they have completed the relevant internal and external processes and requirments, as well as reviewing the adequacy of the candidate, due diligence and role effectiveness.

Conduct Rules Policy

Covering both tiers of Conduct Rules (Individual & Senior Manager), our Conduct Rules Policy details a firms objectives in complying with the conduct rules, developing adequate training for employee and effective processes for conduct rules breach reporting.

Conduct Rules Training Guidance

As part of their fitness and propriety responsibilities, firms are expected to offer training to all relevant employees on the Conduct Rules and to evidence that training and the employees’ understanding. Each firm regulated under the Senior Managers & Certification Regime (SM&CR) must develop adequate and effective training programs that cover the Conduct Rules and are relatable to each employee and their job role. Whilst it is difficult for us to provide an actual training program due to the bespoke nature of each firm; we have included in our SMCR Pack, an extensive guidance document covering how you can develop SMCR training; the areas to cover; how to format the training, and examples and relevant information relating to each conduct rule.

Certification Functions Certificate Template

Certificate template for employees performing a certification function role within your organisation. Section 63F of the Act (and section SYSC 27.2.9 G of the FCA Handbook) states that a certificate issued by a firm to a person must: –

  1. state that the firm is satisfied that the person is fit and proper to perform the function to which the certificate relates; and
  2. set out the aspects of the affairs of the firm in which the person will be involved in performing the function
Firm Type Assessment Guide

There are 3 types of SM&CR Firm; Limited; Core and Enhanced, each with different Senior Management Functions and Prescribed Responsibilities. We have added a simple guide to help firms understand which firm type they are and which SMF’s and PR’s apply to them.

Employee Training Policy & Templates

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.

Whistleblowing Policy

It is essential that employees are aware of their obligations under the SM&CR and that they are supported and protected if it comes to reporting and disclosing information about breaches of the regime or Conduct Rules. Our Whistleblowing Policy covers the legal requirements under the FCA and PIDA.

Recruitment & Induction Templates

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 (new)
  • Recruitment & Selection Policy (new)
  • Job Description Template (new)
  • Sample Interview Questions (new)

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