Senior Managers and Certification Regime ("SMCR") - key deadline upcoming on Tuesday 7th March 2017

One year on, Tuesday 7th March 2017 is a key date for deadlines in the Senior Managers and Certification Regime

• The Conduct Rules, which have applied to staff caught under the SMCR since March 2016, will apply to all remaining staff (with the exception of those staff whose roles would be fundamentally the same as if they worked for a non-financial firm, e.g. post room staff, receptionists and cleaners) from 7th March this year.

• Rules on the requesting and giving of regulatory references as part of the assessment of potential new recruits as ‘fit and proper’ under the SMCR, come into force on 7th March.

• Finally, the deadline for firms to issue certification for individuals under the Certification Regime, including those carrying out wholesale activities, such as algorithmic and high-frequency trading is also 7th March.

The indications are that the regulators will hold those who have signed off the certification certificates personally responsible if things go wrong. In an interview with Bloomberg TV last year, Mark Carney said that if there are problems on the trading room floor, not only would the regulator hold the trader personally accountable, but the trader’s boss and the boss’s boss for not having the proper controls and systems in place. FMCR can provide the skills to assist with the assessment of those carrying out activities in the wholesale markets, particularly in complex products and algorithmic trading.