Guidance on Expansion of Senior Managers Regime to Fund Managers and Others

In 2016, the U.K.’s Senior Managers and Certification Regime (SM&CR) went into effect for the banking industry, introducing a heightened level of personal responsibility for senior managers at those institutions. The following year, the U.K. Financial Conduct Authority (FCA) took steps to expand the SM&CR to cover all sectors of the financial services industry, including private fund managers. This article outlines the portions of three consultation papers issued by the FCA pertaining to the transition of FCA-regulated firms to the SM&CR that are most relevant to private fund managers. The implementation date for affected firms to transition to the SM&CR is currently slated to be December 9, 2019. For more on the SM&CR, see “FCA Chief Executive Touts Senior Managers Regime and Remuneration Restrictions As Important Incentives to Promote Good Culture at Fund Managers” (Apr. 12, 2018); “FCA Director of Enforcement Details the Goals and Tenets of the Agency’s Senior Managers Regime and Proposed Modifications to Its ‘Early Settlement’ Program” (Feb. 16, 2017); and “FCA Enforcement Director Emphasizes Responsibilities Under Senior Managers Regime” (Jun. 2, 2016).

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