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Evidencing “reasonable steps”: An SMF’s guide to surviving FCA scrutiny

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John Higgins and Maria Symeon share practical advice on documenting oversight, managing delegation, and evidencing challenge.

​Under the FCA’s Senior Managers and Certification Regime (SMCR), personal accountability is tested when regulatory issues arise. Under the statutory Duty of Responsibility (FSMA s66A) and the FCA’s decision-making guidance in DEPP 6.2, Senior Management Function (SMF) holders are not judged by the pursuit of perfection, but

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