Paradigm Mortgage Services, the mortgage services proposition, has today (18th March 2019) announced the launch of a new free Guide for all directly authorised advisory firms covering their responsibilities under the FCA’s Senior Managers & Certification Regime (SM&CR) and how they can meet them.
The SM&CR is already in place in the banking industry (from March 2016) and came into force for product providers in December 2018. As it stands, advisory firms are currently regulated under the FCA’s Approved Persons Regime however this will be replaced by the SM&CR from the 9th December 2019.
The overriding requirement that the SM&CR brings about for financial services firms is that senior management must evidence good culture and ethics, and this is to be driven from the top.
Paradigm has produced its free SM&CR Guide to provide firms with an overview of the new regime and the key points it covers including senior management functions, the certification regime, and the conduct rules that come with it.
Senior management will also be expected to write their own ‘Statement of Responsibility’ (SOR) to confirm the personal responsibility they are taking for the conduct of their firm, while senior managers will also certify annually that certain individuals within the firm are fit and proper, and competent to perform a controlled function.
The Guide also analyses where the duty of responsibility lies, where firms should start in terms of their preparations for the new regime, the immediate actions that are required, plus it covers the support which is available via Paradigm.
The Guide is available to all advisers, not just members of Paradigm, and to back up the guide, at all Paradigm’s 2019 mortgage masterclasses, Christine Newell – Mortgages Technical Director – will be providing help and support on the SM&CR as part of her regular compliance update.
In addition, Paradigm is running two, half-day ‘Best Practice’ events this June in Tunbridge Wells (11th June) and Bristol (13th June) which will focus solely on preparing for the SM&CR. Attendees will get a full run-down on the changes that need to be implemented and will be provided with resources and tools in order to ensure their firm’s compliance – topics under consideration include: culture and leadership within a firm; the approach to rewarding and managing people; governance arrangements; the SM&CR; and the duty of responsibility for firms. These events are open to all advisers, not just existing Paradigm members.
Bob Hunt, Chief Executive of Paradigm Mortgage Services, commented: “With less than 270 days to go until the implementation of the SM&CR regime, advisory firms should be undertaking the work required in order to ensure they meet the new standards.
“The SM&CR is all about leadership and culture within a regulated advisory firm. The clear expectation is that business owners take the lead in this and, not only take responsibility for their own actions but also leading their entire firm. It also means that every member of staff who interacts with a customer or performs a role that could affect the outcome of any advice or services provided to that customer must meet a certain standard of behaviour set by the business owners, and that they adhere to the conduct rules at all times.
“This Guide on the SM&CR not only provides an overview of the requirements but it also steers firms in the right direction so they can begin work immediately and ensure they meet the 9th December deadline. Given this is an industry-wide issue, we’re very pleased to make this available to all intermediary firms, as part of our ongoing support to firms ahead of SM&CR. In addition to the support available on our website, directly authorised firms attending one of our CPD events will also benefit from detailed information and analysis from Paradigm staff in order to help them fulfil their SM&CR obligations.”