On 18 December 2020, the UK Financial Conduct Authority published updated information on its expectations to help solo-regulated firms apply the Senior Managers & Certification Regime (‘SMCR’) following the exceptional circumstances of COVID-19.
This follows the FCA’s publication in April 2020.
The FCA:
– says it expects firms’ application of the SMCR rules will shortly return to normal;
– maintains its position that firms do not need to have a single Senior Manager responsible for a firm’s response to COVID-19;
– says its relaxation of the requirement for firms needing to make temporary arrangements because of COVID-19 to submit updated Statements of Responsibilities (if certain conditions were met) will end on 7 January 2021 (but firms do not need to submit updated Statements of Responsibilities for changes before 7 January 2021);
– confirms the opportunity to modify by consent for temporary arrangements for senior management functions lasting longer than 12 weeks will end on 30 April 2021 (and all consented modifications will end on 30 April 2021); and
– has made very little change to its position on furloughed staff.