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Senior Managers (SM) and Certification Regime (CR) Update


In 2016 we reported on the Government’s announcement to extend the SM&CR to non-banking regulated financial services firms, which includes investment firms, asset managers, and consumer credit firms.

While the consultation period was open until 3 November 2017, firms must be able to evidence the reasonable steps they have taken to prevent a breach of the rules, including:

  • Examining internal processes and procedures with regards to the new or expanded requirements under the regime.
  • Review of internal indemnification agreements to make sure they apply to appropriate individuals.

Consideration should also be given of existing directors and officers (D&O) policy and whether the appropriate individuals are included under such policy, as well as consider adequate limits.

Please contact us for further information on reviewing your existing D&O insurance arrangements in light of these changes.