How are you coping with the FCA’s new Form A (and supporting documentation)?

Feb 21, 2022 12:00:00 AM

What’s happening?

Some firms have, apparently, not been made aware of the additional assessment requirements applying to Senior Managers & Certification Regime (SM&CR) Firms and their Senior Managers when it comes to the SM&CR Form A (both Long and Short versions of the Form). In both versions, there is an additional section 6.03 requiring firms to provide details of their assessment of the Senior Manager (i.e. the applicant). The requested information must be provided for the Senior Manager when an SM&CR Form A is submitted to the FCA. This also includes internal hires.

In addition to the usual SMCR compliance competency and capability questions, section 6.03 also requires firms to provide, together with the Form A, a range of supporting information and/or documentation, including the applicant’s Statement of Responsibilities and CV, the firm’s skills gap analysis of the applicant, the applicant’s induction programme and learning and development plan and how the assessment of competency for the specific senior management function was arrived at. Firms must prepare and submit the documents requested by section 6.03 with their applications for SMCR compliance. Sending them later will delay approval due to missing information, as the FCA case officer will wish to assess a complete application quickly and without the need to seek additional information. Each time the case officer has to contact the firm for extra detail, the clock stops and work on the application will cease.

Section 6 is where the applicant and the Firm can set out their case to the FCA, highlighting why they consider the individual to be appropriately skilled and experienced to perform the senior management role.

What do you need to do?

The SMCR compliance requirements apply to all Senior Managers & Certification Regime firms (i.e. Limited scope, Core and Enhanced firms). Firms must appreciate the need to provide this information in full if their Senior Managers are to be approved.

How can we help you?

Our specialist team can provide effective guidance and assistance with any aspect of the Senior Managers & Certification Regime, including Senior Manager approval applications and Form A packs and the related due diligence documentation.

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