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MFA and AIMA Submit Comments to the U.K. FCA on the Senior Managers & Certification Regime (SMCR)

Today, MFA and AIMA submitted a joint comment letter to the U.K. FCA in response to its consultation paper on applying the SMCR to asset management firms.  In our comment letter, we expressed our general support for the proposals set out by the FCA and asked the FCA to provide additional flexibility with respect to the application of the regime to senior managers, in light of differences in governance arrangements used by different firms.  We also suggested the FCA propose a central register of certified persons that regulated firms could access, rather than requiring firms to publicly post information about certified persons on a firm’s website.  We also encouraged the FCA to consider how best to adopt a central register without imposing undue administrative burdens on firms.