SMCR has already rolled out to banks and insurance companies and after December 9 it will apply to all 47,000 companies the Financial Conduct Authority regulates.
Under the regime anyone who holds a senior management function will need to be approved by the FCA and every senior manager will need to fill out a statement of responsibilities explaining what they are responsible for.
Nucleus has now published a guide to help advisers finalise their preparations in the final countdown to the new rules, in partnership with Phil Young, managing partner at adviser support firm Zero Support.
The guide covers the senior manager rules, statements of responsibility and annual ‘fit and proper’ assessments", as well as the wider implications of the rules on references and employment law.
Garry Mcluckie, communications director at Nucleus, said the introduction of regulations was "often far from smooth".
He said: "As we have seen with Mifid II, despite the long build-up there can be confusion around the practical steps advisers need to take to comply.
"We hope this white paper is helpful in providing clarity on the requirements under the SMCR and what firms need to do to comply with these new rules.
"For companies that already have a positive culture and clear governance processes in place this shouldn’t prove too much of a challenge."
Founded in 2006 by seven advice businesses, Nucleus currently provides wrap platform services to 1,370 active advisers with assets under administration of £14.8bn.
The FCA hopes SMCR will help establish healthy cultures and effective governance in companies by encouraging greater individual accountability and establishing a new standard of personal conduct.
Alarm bells were sounded this year over the general preparedness of the advice industry for the new requirements under SMCR, with Linda Gibson, director of regulatory change and compliance risk at BNY Mellon’s Pershing, warning in September that advisers remained "largely unprepared".
In June paraplanning expert Cathi Harrison, director and founder of paraplanning support services provider Para-Sols, told Intelliflo’s Change the Game conference most firms were underestimating the amount of work needed to prepare for SMCR.
But Phil Young, managing partner at Zero Support, said some of the issues raised under SMCR were not new but re-enforced regulatory requirements advisers may have missed previously.
Mr Young said: "In particular, the changes to references and the use of compromise agreements are worth keeping an eye on.
"This guide has been written with advisers and planners in mind. While the aims to change culture and behaviour appear optimistic, the underlying requirements aren’t as daunting as some would have you believe."
The guide warns advisers SMCR will also extend to reference requests for employees leaving their firm, including disclosing six years’ worth of information on previous employees.
The guide highlights this can include disciplinary or conduct issues and warns advisers against signing non-disclosure agreements or settlement agreements which could hide these issues in future.
rachel.mortimer@ft.com
What do you think about the issues raised by this story? Email us on fa.letters@ft.com to let us know.
