The Senior Managers and Certification Regime (SM&CR) is to be extended to all FCA authorised firms from 9 December 2019 and will affect all threesixty clients. Most of the implementation details have already been confirmed but earlier in the year the FCA consulted on some minor changes to certain parts regime. The FCA has published a Policy Statement setting out its final position on these areas.
The issues most likely to affect threesixty clients are:
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