FCA consultation paper on the senior managers regime SMR

The SMCR is a critical piece of work for one simple reason. It is not EEA inspired.

It is also high on the agenda of the FCA business plan. And it appears relatively un reported in the financial adviser community, at least compared with all the scaremongering about MifiD 2 that won’t apply to the vast majority of IFA advisers firms anyway who are either PIF firms or mortgage and general based.

Here is one alarming line:

“We propose applying the Conduct Rules to a firm’s regulated and unregulated financial services activities (including any related ancillary activities). For example, an activity carried on in connection with a regulated activity.”

Now this is only a consultation paper, but any IFA firms that do conduct unregulated activities, such as bookkeeping, second charge and bridging mortgages, will need to be acutely aware of this, and look to split out their regulated work with clear boundaries. The problem comes with the ancillary work around the regulated advice piece. Most advisers treat all as one, and as regulated, but recent moves to split out discrete work into non regulated and generic will have to stop - the conduct rules may apply to all activities.  Not a worry for most, as most treat all under the higher regulatory standards.

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