On April 23, MFA and AIMA submitted a joint comment letter to the UK Financial Conduct Authority in response to the FCA’s consultation paper on Optimising the Senior Manager & Certification Regime (SMCR). In our letter, MFA and AIMA agreed with the FCA’s proposal to exclude the Head of Legal from the requirement to be approved as a Senior Manager. We also expressed agreement with the FCA’s proposal to exclude individuals in the Client Dealing function who have purely administrative responsibilities should be excluded from the scope of the SMCR and we encouraged the FCA to provide additional examples to provide greater clarity as to the scope of individuals within the Client Dealing function who are within scope of the SMCR. Finally, we supported FCA’s proposal that individuals who have systems and control functions, but who do not require approval as senior managers under the regime, should be included in a new Certification Function.
