The Government announced in 2015 that all regulated firms will be subject to SM&CR from 2018 which has led the FCA to produce proposals for the extension of the regime. Operational aspects and transitional arrangements will be subject to a separate consultation at a later date. This is effectively the starting gun for a long marathon of regulatory change. Generally the FCA believes that all partners in a firm will be Senior Managers (based on the assumption that partners have influence over how a firm is run) and there is a partner senior management function, for that purpose (SMF27). There are a number of lessons learnt from the Bank Regime. Misleading others within the firm about the credit-worthiness of a borrower. One aspect of the regulatory reference regime is that firms must update any regulatory references given where new significant information comes to light. There are permitted grace periods within which staff can temporarily carry out a certified staff role without being certified where certain conditions are met which are similar to the current Approved Persons Regime. There is no need to also allocate overall responsibility for the Finance function to the senior manager already approved as SMF 2. In addition, the FCA also requires a firm to ensure that these Statements of Responsibilities are kept up to date (discussed below). The FCA is proposing to consult on what, if any, requirements it may introduce for appointed representatives and has not given a timetable for this consultation. Persons subject to the rules in COCON should consider how their actions (or their failure to act) can affect the interests of customers or result in customers being treated unfairly. As it is relevant to commentary that follows in this note, it is worth commenting on the additional work that the FCA has done since implementation of the Bank Regime. So it is prudent to consider the tone and content of the map and align the tone with the FCA’s wider expectations, including treating customers fairly, conduct risk, culture (particularly a culture of challenge in this context) and their focus on management information. Firms within the scope of the SMCR must ensure any senior manager carrying out one or more function is approved by the FCA before carrying out that function. Any sharing of responsibilities, especially where it may be viewed as unusual by the FCA, needs to be clearly explained. The rules for Senior Managers cover certain individuals who are subject to approval by the regulator. Evaluate a firm’s disciplinary processes and whether it is likely that any changes will be needed, particularly with difficult leavers and with certification staff and the new regulatory references regime.