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Significant IFPRU firms (you'll know if you are one!); Firms with assets under management of £50 billion or more; and other large mortgage lenders.
Individuals who are approved persons within the approved persons regime will automatically be transitioned into the applicable Senior Manager functions (SMF) on commencement of the new regime, without any need for further action by you.
There will be no need for re-approvals or any background or criminal records checks for individuals already approved.
Current Controlled Function
New SMR controlled function
|CF1 Director||SMF3 Executive Director|
|CF4 Partner||SMF27 Partner|
|CF10 Compliance oversight||SNF16 Compliance oversight|
|CF11 MLRO||SMF17 MLOR|
|CF30 - IFA|
no longer a controlled function on FCA register.
Senior managers above will take all responsibility.
Although you are not required to submit it to the FCA, you will need to prepare a Statement of Responsibility for each approved person who is transitioning into a SMF. And IFAC will audit this from January 2020.
Ongoing applications for approval of individuals under the current regime will continue to be accepted right up to implementation day and then they will be automatically converted to SMF applications.
Our experience is that the new regime will have a profound impact on bigger firms, but little impact on the IFA / MGI firm. For big firms the impact will be around staff training, employment contracts, references, fit and proper and procedure manuals.