Context
In its most recent Regulatory Round-Up e-mail (sign up for FCA e-mail updates here), the FCA has provided an update on SMR and CF (AR) applications.
Key points to note
- The FCA communicated in December 2020 about the delays in determining SMR (Senior Manager Regime) and SIF (Significant Influence Function) applications, following the large volume of applications received before the extension of the Senior Managers and Certification Regime (SM&CR).
- The FCA increased resourcing to address the delays and made good progress in determining most applications which had breached their statutory deadline and reducing the allocation times for applications.
- However, in Q1 2021 the FCA received significantly higher volumes of applications than it forecast. As capacity was down due to Covid-19, the FCA was not able to bring its case volumes and allocation times back to business-as-usual levels by the end of the financial year as planned. Therefore, the FCA has apologised that applicants may still face delays while it increases resources.
- Applications to hold a Controlled Function at an Appointed Representative that are both routine and non-routine are dealt with by the same teams that handle Senior Manager applications. Because information about such candidates will be examined in detail, these also take longer to determine. The FCA has said that firms can help it to process applications as quickly as possible by:
- carefully checking the application before submission to ensure that it has been completed in full
- remembering that for SMR applications you must complete a Disclosure & Barring Service (DBS) check before submission
- making sure you have conducted, and included, all appropriate due diligence checks, including regulatory references, before submitting a candidate
- responding promptly and fully if the FCA contacts you to seek further information about a submitted application.
Next actions
None – for information and awareness