Firms regulated by both the FCA and PRA are expected, in respect of the Senior Managers and Certification Regime (SMCR), to:
- resubmit relevant Statements of Responsibilities as soon as reasonably practicable taking into account the current circumstances;
- reallocate those Senior Management Functions’ (SMF) Prescribed Responsibilities (PRs) of a temporarily vacant SMF among their remaining SMFs until a permanent replacement is identified and approved subject to the updating the regulators if firms rely on the "12-week rule" (the maximum period an individual is allowed to perform a SMF without apoproval) ;
- to designate a SMF 1 individual for the identification of ‘key workers’ and a SMF 24 individual for responses to the coronavirus situation including business continuity, information security and outsourcing;
- furlough ONLY as a last resort individuals performing SMF 1, SMF 2, SMF 16, SMF 17, SMF 19, SMF 25, SMF 26 and SMF 29 for the relevant firms; and
- continue to take reasonable steps to complete any annual certifications of employees that are due to expire while coronavirus restrictions are in place.