We are reporting the findings of our in-depth supervisory review of the Statements of Responsibilities (SoRs) and responsibilities maps supplied with grandfathering notifications for firms.
It was clear that most firms had engaged with the challenges of implementing the SM&CR and had invested a considerable amount of effort in preparing for it.
In most of cases that we looked at, firms had considered how the SM&CR applied to them. They had identified Senior Managers and allocated Senior Management Functions and responsibilities.
We also identified some issues where we believe that some firms are not meeting our rules and guidance, as set out in the Handbook.
Who this applies to
This applies to firms in scope of the SM&CR:
- building societies
- credit unions
- Prudential Regulation Authority-designated investment firms
What you need to do
We have either already contacted firms in the scope of our review or will contact them in the near future with detailed observations relevant to them.
Firms should review their SoRs and management responsibilities maps in light of this feedback and, where necessary, revise them using the rules and guidance from the Handbook. Where this is required by our existing rules, they should resubmit revised documents.
Where firms identify changes to documentation they have already submitted, they should notify us as required by the rules. In particular, where there is a significant change to the responsibilities of a Senior Manager, firms should notify us using Form J.