Who will manage the managers under the SMCR?

Performance management of an employee under the SMCR is subject to the same considerations as for the contractual arrangements and dismissal procedures pertaining to any senior staff member. However, the regulatory framework provides for some additional and specific considerations, explains Alexandra Carn.

Alexandra Carn(alexandra.carn@edwincoe.com) is a partner who specialises in employment matters at law firm Edwin Coe. She has particular expertise in matters relating to financial services, acting for both PRA and FCA-regulated individuals and companies.

The Senior Managers and Certification Regime, which came into force on 7 March 2016, currently covers individuals working for UK banks and building societies including branches of foreign banks operating in the United Kingdom. For those persons it effectively replaced the ‘Approved Persons’ regime.