The introduction of the Senior Managers and Certification Regime (“SMCR”) a year ago has seen an increased focus on accountability and standards of fitness and propriety. For those firms within the new regime, this has meant reviewing how they assess individuals as fit and proper, both when hiring senior managers and certification staff and when running their first annual certification process.

To assist firms looking for specific guidance as to how best to do this we set out links below to documents published by the Banking Standards Board (“BSB”).

Although these publications are aimed at banks and building societies, they will also be of use to other regulated firms, particularly in view of the proposed extension of the regime next year to all FSMA regulated firms.

Please see below for quick links to the BSB statements:

• Statement of Good Practice 1 – Certification Regime: Fitness and Propriety Assessment Principles … this document sets out a number of principles on how to assess the fitness and propriety of staff under SMCR.
• Supporting Guidance to Statement of Good Practice 1 – Certification Regime: Fitness and Propriety Definitions, Sources of Information and Assessment Record Template … this is practical guidance on the various elements of Fitness & Propriety and relevant sources of information, including a Fitness and Propriety Assessment Record Template. While this is guidance rather than mandatory, it is nonetheless a good resource for HR and Compliance professionals with responsibility for monitoring and managing fitness and propriety, including certification processes.

If you have any questions or would like to discuss how best to integrate this guidance into your internal processes, please contact a member of the Kemp Little team.

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