Senior Managers & Certification Regime

The FCA has now published its Policy Statements on the implementation of the SMCR, which will, for insurance brokers, be effective from 9 December 2019.

Two Policy Statements have so far been released: 

PS 18/14 – Extending the SMCR to FCA regulated firms;

and PS18/16 – The Duty of Responsibility.

In addition, a useful guide for regulated firms about SMCR implementation has been produced and we would urge all firms to download a copy and familiarise themselves with what is to come. The SMCR guide can be downloaded at

As you would expect, there is a significant amount of detail in these papers and RWA will be considering these carefully over the coming weeks and will be issuing further guidance and bulletins once the information has been digested and fully understood.

About the author

Terence is the Compliance Director at RWA. He has over 35 years' experience in the Financial Services environment, covering general insurance, investments and mortgages. Before joining RWA, Terence worked for a large PLC insurance brokerage in Manchester, overseeing some 20 acquisitions. He was made a Director of RWA in 2011 and has worked with insurance broking firms of all sizes across the UK. He has a particular interest in Financial Crime and the protecting the insurance broker. Terence is also Executive Chairman of the Association of Professional Compliance Consultants (APCC), the professional body for the compliance consultancy sector.

Terence Clark

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