In response to COVID-19, the FCA has extended the deadline by which solo-regulated firms need to have implemented the Certification Regime from December 2020 to March 2021. The decision seeks to give those significantly affected by the pandemic additional time to fully implement the second string of the Senior Managers & Certification Regime.
David Blunt (Head of Conduct Specialists at FCA) said back in July that he hoped the extra time will give firms and senior managers space to make sure that they have an adequate, robust and effective response to Coronavirus challenges (including a dispersed workforce) and that it will give firms time to ensure they are putting in place the highest standards of SMCR compliance. Read more on the new FCA process here.
The decision is a pragmatic one, but firms now face a decision. Will they use this additional time to cement an infrastructure for implementation and meaningful ongoing compliance, or treat certification as a last minute box-ticking exercise and therefore neglect the regulation's core purpose. As Jeremy Smith argues below, both reveal much about a firm's culture.
Clear initial objectives supported by regular supervision activities allow for early identification of potential shortfalls, for development plans to be agreed and set in place to provide support and improvement, or for the harsh realisation that the individual may not be suitable for the role. It will also allow time for all parties to agree amicable resolutions. Continual assessment avoids uncomfortable surprises. Your approach to the Certification Regime makes a huge statement about the culture of your firm, which, ultimately lies at the heart of FCA compliance.