From 9 December 2019 47,000 FCA solo-regulated firms will become subject to the Senior Managers and Certification Regime ("SM&CR").
Even for "limited-scope" and "core" firms, which will benefit from a degree of automatic transitioning to the new regime, several important issues require careful consideration well in advance of the 9 December 2019 commencement date.
Having advised Banks ahead of the March 2016 implementation of the Banking SM&CR, and a number of solo-regulated firms on the extension, we set out the five issues which will require the most careful consideration in the weeks ahead.
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