Under the Senior Managers & Certification Regime (SMCR), regulated firms that haven't updated their Directory during the course of the year are required to report to the FCA that the information they've previously reported remains accurate and up-to-date.
What needs to be done
Last year, firms were required to certify to the FCA that their representatives were properly trained. The deadline for certification last year was March 31. Once they had been certified, those representatives were listed in the FCA's Directory, which is published online as part of the FCA's Financial Services Register. Firms are required to update the Directory for changes during the course of the year, but if there have been no changes, then the firm must confirm that the information in the directory remains accurate and up-to-date at least once a year.
When the confirmation needs to be filed
The confirmation must be made no later than the first business day following the end of the anniversary of filing. For example, if a firm made its last filing on last year's deadline of March 31st, 2022, then the annual update this year must be submitted no later than April 3rd, 2023, which is the first business day after March 31st, 2023.
Which firms must file?
We're talking about a requirement to confirm the information you've previously filed, so the requirement applies to firms that have previously filed, and haven't updated their information during the course of the year. If you filed last year and haven't updated your information during the course of the year, then you need to file the confirmation. The reference to the FCA Handbook for the requirement to confirm the information in your FCA Directory filing is SUP 16.26.18.
How we can help
PartnerVine sells a set of e-learning training modules called SMCR Academy. SMCR Academy has been prepared by Simmons & Simmons to support training your employees on their role specific responsibilities in relation to SMCR compliance. The set of training modules is available for GBP 100 per employee, and has been prepared to work with your SCORM-compliant Learning Management System (LMS).
Simmons & Simmons is selling SMCR Academy on PartnerVine. SMCR Academy is a set of 11 e-learning modules to support firms in their training for SMCR certification. To go to the SMCR Academy product page, click here.
For a review of SMCR Academy, go here.
For more information on SMCR, go to our article About the SMCR.
For a review of SMCR courses and materials online, see our article Review of SMCR Courses Online.
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About Simmons & Simmons
Simmons & Simmons ("Simmons") is an international law firm with more than 1,500 lawyers and 23 offices in major business and financial centres around the globe. Simmons specializes in financial services regulation in the UK, with extensive knowledge of the SMCR and the FCA's practice implementing it. The leaders of the Simmons team behind SMCR Academy are Darren Fox, Andrea Finn and Penny Miller. Simmons publishes a dedicated newsletter on SMCR, called SMCR View. SMCR View provides timely updates on SMCR developments and regulatory announcements, along with tips to assist in managing your SMCR compliance. In addition, Simmons & Simmons has a dedicated web page in relation to SMCR. If you need more than the e-learning solution offered by Simmons on PartnerVine, you can find a full overview of Simmon's products and services there.
This article is not to be considered legal advice and is not a substitute for advice from qualified legal counsel. You may not rely on the information in this article. Material aspects of the discussions in this article may change at any time and without further notice.