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    John O'Dwyer

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    How does the implementation of SM&CR impact CASS firms

    How does the implementation of SM&CR impact CASS firms

    Implementation of the Senior Managers and Certification Regime is currently underway and may well have an impact on your firm’s existing CASS arrangements. This is because the FCA, as part of the SM&CR rules, has introduced a new Prescribed Responsibility for firms...

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    COVID-19: Is the regulator cutting CASS firms some slack?

    COVID-19: Is the regulator cutting CASS firms some slack?

    FCA,  breach management,  CASS,  client assets,  audit trail

    With the unprecedented levels of support coming from government to numerous business sectors to mitigate the impact of the COVID-19, Senior Managers at CASS firms could have been forgiven for looking eagerly to the FCA’s responses last month about COVID-related...

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    HR & Compliance – Bridging the Gap in SMCR

    HR & Compliance – Bridging the Gap in SMCR

    governance,  accountability,  culture,  SM&CR,  competence

    Since the introduction of the Senior Managers and Certification Regime (SM&CR), it has been interesting to see how and where firms have allocated most of their resources to comply with the new rules. Implementation tends to follow one of two strategic approaches:...

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    SMCR Responsibilities – Documenting Risks and Controls

    SMCR Responsibilities – Documenting Risks and Controls

    governance,  accountability,  culture,  corporate governance,  SM&CR,  competence

    In light of the turbulence caused by the Covid-19 pandemic, SMCR may have been pushed down the priority list for most firms for now. The disruption has however given rise to a number of practical and compliance challenges which have a direct and imminent impact on...

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