SM&CR – the unintended consequences

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The SMCR (Senior Managers & Certification Regime) has been in place for dual-regulated firms now since March 2016 and rolls out to all FCA (Financial Conduct Authority) solo-regulated firms from December of this year. But has it had the intended impact and outcomes in improving accountability in firms and the consequent intended improvements in conduct behaviour and culture in those firms? Or has it instead had some unintentional and possibly negative consequences? As the regime rolls out to the wider financial services community – requiring major commitment of resources and effort and investment in processes and systems – there need…

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