The SM&CR and the Consumer Credit Sector
Firms have had some considerable time now to digest the FCA’s proposals to extend the Senior Managers & Certification Regime (SM&CR) to all regulated firms – although as everyone will be acutely aware – we still don’t have a confirmed timeline on this! In my experience the proposals present specific and bigger challenges to the consumer credit industry compared to other sectors. Why? Well firstly – consumer credit firms are relative newcomers to FCA regulation (just over three years). As a result – their governance arrangements may well not be as well tried and tested as firms which have been regulated by the FCA for much longer.