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Sturgeon Ventures: SM&CR should have included ARs

Michael Lloyd

December 9, 2019

The failure of The Senior Managers & Certification Regime (SM&CR) to include appointed representative firms (ARFs) and their individuals is an oversight, according to regulatory incubator Sturgeon Ventures.

SM&CR comes into effect today and replaces the Approved Persons Regime.

It aims to improve governance within financial services firms by making individuals more accountable from senior management to certified individuals.

Seonaid Mackenzie, managing partner at Sturgeon, said: “The SM&CR will significantly improve accountability among individuals in the industry, but it needs to apply to ARFs as well if it is to give any kind of consistency across the industry.

“Quite why the FCA failed to include ARs – both firms and individuals – is anybody’s guess but it is a strange omission, possibly made because the regulator is busy preparing for Brexit.”

Sturgeon said that consumers may find it difficult to check whether their financial advisers are fit and proper.

This is because there is a 12-month window for companies and individuals to switch their listing from the current Firm and Approved Persons Directory to the new SM&CR Registry.

The firm also claimed that consumers may also be confused as to why some advisers are ‘certified’ and others are ‘approved’.


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