Financial Services (FCA / SMCR) Screening is a standardised background screening for candidates entering regulated roles within the financial industry. A typical FCA package includes:
- Address Verification
- Credit
- Directorship
- Financial Services Register
- Sanctions
- Criminal
- Professional Qualification
- Gap checks
- Employment (6 years)
Financially regulated roles might include financial advisors, debt administration and collection, insurance brokers, asset managers, investors, credit lenders, credit processors, credit lenders and/or pension providers.
Senior Manager & Certification Regime (SMCR)
In 2019, the Financial Conduct Authority (FCA) introduced a new structure for financially regulated roles - SMCR.
Under SMCR, financially regulated roles are split into two categories: Senior Manager Functions (SMF) on the top tier, followed by Controlled and Significant Harm Functions under the Certified Regime (CR).
Each regulated role has a function code (e.g. CF30, SMF21, etc.) which indicates which scheme the candidate will be working under.
Senior Manager
- Higher level of financially regulated role.
- Applicable to those supervising those who are processing finances.
- Can also be in HR and/or Compliance, as they are responsible for internal audits.
- Must be approved by the FCA.
Certified Regime
- Applies to employees whose role means it’s possible for them to cause ‘significant harm’ to the firm or its customers.
- Certification staff don’t formally need to be approved by the FCA. Instead, firms need to check and certify that they are fit and proper to perform their role on appointment and at least once a year.
- Those in Controlled Functions (e.g. CF21, CF30) or performing significant harm functions (FCA CF) are eligible for a Basic DBS only.
Standard DBS Checks for FCA Regulated Roles
In 2019 the FCA introduced new SMCR Regime (Senior Manager & Certified Regime), where roles previously described as Controlled Functions (and eligible for Standard DBS) were categorised as Certified Functions (CF) and Significant Harm Roles. These roles are no longer eligible for a Standard DBS under the FCA guidelines as the Employer would effectively self-certify employees that perform these roles by conducting their Fit & Proper Assessment as well as Basic criminal check in the UK (Basic DBS).
As part of the SMCR Regime, the FCA also introduced a new category called Senior Manager Regime, specifically for those roles that will have an oversight over the Certified and the Significant Harm Roles employees, as well as carry a higher risk to the financial institution that comes with an influence and impact on shaping company policies, strategy and compliance processes.
It was possible to have a Standard DBS check conducted for this particular role prior to new FCA SMCR Regime taking effect in 2019, however in line with the new FCA SMCR Regime guidelines this role is not eligible for a Standard DBS check
Please see the FCA Handbook, if you require more guidelines on these checks https://www.handbook.fca.org.uk/
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