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 £175 (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.

Our SMCR Template Toolkit was updated in January 2023 to include The Consumer Duty Instrument 2022 (“the Duty”) additions to the COCON modules. Conduct Rule 6 – Consumer Duty extends the existing conduct rules and states that in relation to retail market business “You must act to deliver good outcomes for retail customers”. This rule supersedes Principles 6 & 7 for retail customers and comes with extenisive new rules under PRIN 2A. The Duty comes into force on 31st July 2023, but there’s no time like the present to implement new regulatory changes and rules.

The SMCR templates have now been updated and added to, ensuring ongoing and future compliance needs are considered and met. In addition to training guidance for Conduct Rule 6 – Consumer Duty being added, we have also updated the Skills Gap Analysis Tool (Excel) and added new skills gap analysis forms, templates and procedures to the toolkit. 

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.

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. 

Our exclusive SMCR Template Toolkit now includes 4 unqiue skills gap analysis tools and templates to meet the SMCR and FCA requirement in this mandatory area. Completing a skills gap analysis is also a key business function that is applicable to all business types and industries. Our tools and templates assist you in identifying, assessing, analysing and reviewing desired skills within your business and industry. 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. 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.

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.

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.

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 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.

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.

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.

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.

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.

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

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.

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 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.

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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