Firms will need to consider whether any individuals in group entities require approval as Senior Managers.

Introduction -

Much has already been written on the proposed extension of the Senior Managers & Certification Regime (SMCR) — with a recent flurry of activity following publication of the FCA’s long-awaited Consultation Paper 17/25 (the CP) (see Latham’s earlier Client Alert, which provides a high-level summary of the proposals).