Last week, NFDA attended a Financial Conduct Authority (FCA) roundtable to discuss the Senior Managers and Certification Regime, which will replace the Approved Persons regime on 9 December 2019.

The FCA discussed their priorities and intended outcomes, which is to change management culture as a path to reducing consumer harm. The FCA also discussed some of the lessons learned from the regime’s implementation in the banking sector, highlighting the benefits of more clearly defined senior management roles and urged senior leaders to engage with the regime as early as possible.

Firms must identify their Senior Managers and Certified Roles and train those staff in the Conduct Rules by 9 December 2019. They will then have until 9 December 2020 to complete fitness and propriety assessments and certify relevant employees.

Whilst the FCA will monitor firms in three tiers (core, limited scope or enhanced) based on information they receive, it is advised that members complete their own assessments to determine which tier is best suited for them and challenge the automatic categorisation if they believe they have been miscategorised.