Delving into the Duty of Responsibility

Many view the SMCR as an extension of the Approved Persons Regime, but it goes beyond APER in a number of ways, including the introduction of the new Duty of Responsibility for Senior Managers and a broader remit to all staff involved in the regulated business. Phil Deeks draws out the details.

Phil Deeksis technical director at TCC (formerly branded The Consulting Consortium). He has nearly 20 years of experience in risk, regulation, compliance and conduct, including within the group compliance function of a large financial services group, and as a technical specialist within the life insurance and financial advice sector team of the Financial Conduct Authority.

The Senior Managers and Certification Regime will replace the existing significant functions under APER and cover those individuals who have overall accountability for a firm’s activities, are key decision makers and have the potential to impact market integrity negatively or create harm to consumers.