As we all drag ourselves back into the office after the summer break, offering up our exotic office treats, it occurs to us all there is work to be done.
For advisers, one of the most pressing things to get on with over the next few months is the Senior Managers and Certification Regime, which comes into effect in December.
Some will already be up to speed, some will simply be putting the finishing touches to their statement of responsibilities and others may well be taking a more relaxed approach. But whichever one of these you fall into, the deadline is approaching.
Fortunately for many advisers, there will be relatively little work to do: the regime is constructed in such a way that the smaller your business, the lighter its touch will be.
At its core, the regime aims to embed individual responsibility at the heart of everything advisers do.
It will mean most areas of an advice company will need a named individual to be personally responsible for its activities. There will be no escape and no passing the buck.
For many advisers this will be nothing new: their clients know who they are and will often have a relationship going back many years. In the unlikely event their clients have a complaint, they know exactly where to go.
But that does not mean the bother of complying with the SMCR will all be wasted, because it could help put an end to two of advisers’ most enraging bugbears: phoenixing and the cost of the Financial Services Compensation Scheme.
It will help the Financial Conduct Authority keep track of who is misbehaving and how they are doing so, which will hopefully lead to earlier intervention. It will also hopefully make it harder for an unscrupulous adviser to drop off the radar and surface elsewhere. Combined, this can help push down the cost of the FSCS that advisers have to bear.
If that does not provide you with an incentive to get cracking after your summer break, then who knows what will.
damian.fantato@ft.com
