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Adviser: Asset Managers and Non-banks Soon to be Caught by the Senior Managers Regime


On 15 October 2015, the UK Government announced an extension of the Senior Managers and Certification Regime (SMCR) to asset managers and other financial services firms in the UK financial services industry.

We have created an update on the forthcoming changes. While the exact details of the expanded regime will be the subject of regulatory consultation, it is expected to reflect the different sizes and types of institutions involved. However, it is broadly expected to comprise a three-tiered approach in-line with the SMCR and in accordance with the following three levels of responsibility:

  1. A Senior Manager Regime.
  2. A Certification Regime.
  3. Rules of Conduct.

Firms should be putting in place the necessary infrastructure to support the changes required and should be reviewing their D&O insurance arrangements to ensure that policy terms and conditions will respond adequately to the risks faced by senior management under the new laws. Please contact us for further information on reviewing your existing D&O insurance arrangements in light of these changes.