Implementing the senior managers regime: Some practical considerations

Douglas Cherry, partner at Reed Smith, takes a closer look at the implications of the new regulations for asset and wealth management employees.

Background In July, the FCA released its consultation paper  (CP) on the extension of the Senior Managers and Certification Regime (SMCR) beyond the initial roll-out to banks and building societies, to the vast majority of the other firms it regulates, including asset and wealth management firms. Current developments The Senior Managers Regime consists of three principal elements, which are described by the FCA in its CP as the "core", "enhanced" and "limited-scope" regimes.   The core regime applies to all affected firms, whilst the enhanced regime will apply only to the very l...