On 11 October 2018, the FCA published a guidance consultation (GC18/4) on statements of responsibilities (SoR) and responsibilities maps under the Senior Managers and Certification Regime (SM&CR). The purpose of the guidance was to give practical assistance and information to solo-regulated firms, who will be required to prepare these documents from 9 December 2019 when the SM&CR extends to all FCA authorised firms.
A SoR document sets out what a senior manager is responsible and accountable for under the ultimate accountability of a firm’s governing body. In the view of the FCA, a SoR should be “clear and easy for regulators” and contain enough information to “clearly describe the senior manager’s actual responsibilities and accountabilities, but without unnecessary detail.” The FCA also notes that a SoR should be “self-contained and not refer to other documents“.
In contrast, responsibilities maps provide an overview of how a firm is managed and governed. In the view of the FCA, this should contain “key information about governance bodies, senior management reporting lines and senior managers’ responsibilities“. The FCA requires that this information is presented at a legal entity level. Although where a firm is part of a group, the map should show clearly how the firm relates to its group. The FCA also states that good responsibilities maps “usually have a mixture of graphics and text and are easy to navigate and comprehend“.
The consultation goes on to provide examples of questions that firms should consider and outlines examples of good and poor practice in respect of limited scope, core and enhanced firms. The consultation closes on 10 December 2018 and should be read in conjunction with the guides to solo-regulated firms that the FCA published in July 2018.
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