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 by whether they
Evidencing “reasonable steps”: An SMF’s guide to surviving FCA scrutiny
3 min read
John Higgins and Maria Symeon share practical advice on documenting oversight, managing delegation, and evidencing challenge.