We've just updated our online SM&CR Handbook, which now includes information around the transition to the new regime, and additional insights into what we've learned during the consultation periods.
The Handbook's twin focus remains on identifying the main challenges firms will face around implementation, and advice on how to approach the new regime. It also contains some predictions about how the FCA will supervise against SM&CR in practice.
Unless you're an Insurer, the FCA has now confirmed transition will be mid to late 2019 (post Brexit). But, because of the nature of the reform, it's worth firms' senior management and Boards thinking now about where their implementation should focus, and how best to integrate its requirements with the way they want to run their business.
Happy reading, and hope you find it useful. Feedback welcome as always...
The consultation period closed in November 2017, and in December the FCA and PRA published their consultations on the transition arrangements for moving into the new regime. Included are new chapters on the transition arrangements and insight from discussions with firms.