The FCA has published final rules confirming amendments to the SMCR, and final rules for solo-regulated firms.

Key Points:

..The FCA has confirmed that the Head of Legal does not require approval as a Senior Manager, and has clarified the scope of the Client Dealing Function.

..The FCA has also published the final rules setting out the SMCR for solo-regulated firms, and for its new Directory of individuals working in financial services firms.

The FCA has published final rules, amending the SMCR to confirm that the Head of Legal does not require approval as a Senior Manager (if not otherwise performing a Senior Management Function), and clarifying the scope of the Client Dealing Function under the Certification Regime so that it does not capture purely administrative roles. The FCA consulted on these changes, which affect banks and insurers already subject to the regime, as well as solo-regulated firms that will become subject to the SMCR from December (although the status of the Head of Legal is only relevant to “enhanced” firms), in January 2019.