MiFID II communications complianceWith the new SM&CR extending to all FCA regulated firms this December, all financial institutions are bracing themselves and taking action (or at least, they should be). In the words of our Product Advisory Board Chairman Nick Child, “Senior Managers must demonstrate how they monitor and control those actions or inactions and ensure personnel act with integrity, skill and due care. Failure to take those steps would be foolish and dangerous.
The latest changes in the regulatory landscape will see the Senior Managers & Certification Regime come into effect for all 47,000 FCA regulated firms. This includes many buy-side firms, hedge funds and brokerage businesses. Another point causing nervous ripples in the sector is the first enforcements of the New Regime. No one likes to be the first the Regulator makes an example of, as they tend to be the strictest and hence the repercussions more severe.