The UK’s Financial Conduct Authority (FCA) has published a consultation paper on proposals to extend implementation deadlines for the Senior Managers and Certification Regime (SM&CR).
Following the outbreak of the coronavirus pandemic, HM Treasury announced in June that the deadline by which firms must have assessed the fitness and proprietary of Certified Staff would be delayed until 21 March 2021. The aim of the extension was to give firms affected by the pandemic time to adapt to the new environment and to make the required changes.
In line with the Treasury’s extension, the FCA is consulting to extend the deadline for further SM&CR requirements in order to remain consistent across the board. It is proposing that deadlines will similarly be extended for the date the rules come into force and the deadline for submission of information about Directory Persons to the FS register – from 9 December 2020 to 31 March 2021. The FCA will also move to change references in the rules to the deadline for assessing Certified Persons as fit and proper – as announced by the Treasury.
The FCA points out that if firms are able to meet the upcoming obligations before the extended deadline, they should do so.
The consultation closes on 14 August 2020 – the FCA has requested that any comments on the proposal are received before this date.
We recently wrote a blog post regarding Canada’s OSFI and its announcement that it intends to gradually return to making policy developments. Within the blog, we asked whether OSFI’s announcement signified the end of a quieter period of regulatory activity and whether financial institutions should be readying themselves for a slew of new legislation towards the end of 2020. The FCA’s consultation on extending SM&CR related deadlines shows that many regulators are very much working independently on this issue.
For smaller, regional institutions – this independent activity will not pose too much of a challenge. However, for those operating across jurisdictions and multiple borders, keeping on top of regulatory developments from multiple regulatory bodies – deadline extensions, return to work and the rest – may prove challenging.
If anything, the messaging from global regulators only highlights the inconsistencies and the difficulty that firms may face in the coming months as they try to track and analyse regulatory deadlines. As Canada looks to return to normality, the UK proposes to delay implementations even further. Horizon scanning following the unpredictability presented by Covid-19 is challenging at best.
The solution is undoubtedly to employ regulatory technology, such as CUBE, that automates regulatory compliance procedures. CUBE allows firms to automate horizon scanning, enabling staff to focus on implementing and managing regulatory change – rather than spending endless man-hours predicting it.