To simply implement this new regime, using current toolsets, poses a risk to firms falling short to the requirements of the SM&CR regime, Saeed Patel of KRM22 says. In this podcast, Patel discusses the Senior Managers and Certification Regime (SM&CR or SMCR) with IBS Intelligence Reporter Sunniva Kolostyak.The UK regime, which is being extended to almost 50,000 organisations, will come into effect on 9 December, and Patel suggests affected companies should go through the following checklist for compliance:SM&CR checklistDefine your firm type: limited scope, core, enhancedBrief board-level and other senior executives likely to be subjected to SM&CRCreate implementation plan including activities, timelines, resourcing requirements, dependencies and available technology solutionsIdentify which senior managers will have prescribed responsibilities and prepare responsibility statementsIdentify individuals performing certified functions who will require certification by the firmEnsure employment contracts, management structures and job specifications reflect current responsibilitiesNotify the FCA of any changes to certified individuals with prescribed responsibilities and submit senior manager’s FCA applications for approvalUpdate internal appraisal and recruitment processes to include Fit and Proper assessments and appropriate background checksEnsure handbook policy and procedures comply with regulationsRaise company SM&CR awareness through training and company-wide roll out 

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