The Authorisation Journey: Building an SMF Team From Scratch
A firm applying for FCA authorisation is not only building a business — it is assembling a senior management team the regulator will assess before it grants permission. The Senior Management Functions a firm needs, and the people approved to hold them, are central to …
Can One Person Hold More Than One SMF? Combining Senior Manager Roles
At a smaller regulated firm, the question comes up almost immediately: does every Senior Management Function need its own person, or can one individual hold several? The answer is that combining functions is both common and legitimate — but it is not unlimited, and getting …
SMF4: The Chief Risk Officer Function and Why Independence Defines It
The Chief Risk Officer is the Senior Management Function the regulator relies on to be the independent check inside a firm. SMF4 — the chief risk function — is held by the individual with responsibility for the firm’s risk management framework, and the defining feature …
SMF3: What the Executive Director Function Means at a Regulated Firm
At an FCA-regulated firm, sitting on the board is not the same as holding a board title at an unregulated company. An executive director of an authorised firm ordinarily holds SMF3 — the executive director function under the Senior Managers and Certification Regime — a …
SMF20 and SMF23: The Insurance Senior Manager Functions Explained
The Senior Managers and Certification Regime applies to insurers as well as to FCA-regulated firms, but insurers have their own set of Senior Management Functions reflecting how the sector is governed. Two of the most specialist are SMF20, the Chief Actuary, and SMF23, the Chief …
SMF16 vs SMF17: When You Need One, Both, or a Combined Role
uently confused Senior Management Functions are SMF16 and SMF17. Both sit in the compliance and financial-crime space, both are required at most authorised firms, and at smaller firms they are often held by the same person. But they are distinct functions with distinct accountabilities, and …
SMF1 Explained: What Changes When You Hire a CEO for a Regulated Firm
Hiring a chief executive is the most consequential appointment any business makes. At an FCA or PRA-regulated firm it is also a regulated one. The person you appoint does not simply take the title of CEO — they take on SMF1, the Chief Executive function …
Hiring an SMF2-Approved CFO: What the Chief Finance Function Really Demands
When a regulated firm hires a chief financial officer, it is not only appointing its most senior finance leader. It is appointing the holder of SMF2 — the chief finance function under the Senior Managers and Certification Regime — a governing Senior Management Function that …
Board Evaluation: When and How
Board evaluation has a poor reputation, and largely a deserved one. A questionnaire circulated in December, results presented in January, a paragraph in the annual report confirming the board considers itself effective, and nothing changes. Done that way it is a compliance exercise that consumes …
The Company Secretary in an M&A Process
A transaction is the moment a company’s governance record stops being an administrative matter and becomes a commercial one. Gaps that nobody minded for five years are found by a buyer’s solicitors in a fortnight, and they arrive back at the board as warranty requests, …
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