SM&CR

Senior Manager Training

Tailored training for people taking on a Senior Management Function, built on their own Statement of Responsibilities rather than a generic course.

Senior Manager training prepares an SMF holder for the personal accountability the role carries: what their Statement of Responsibilities commits them to, the Conduct Rules, the Duty of Responsibility and the evidence that shows reasonable steps. We deliver it one to one or to a board, in person or remotely, and give the firm a written training record for its fitness and propriety file.

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Speak to a licensing expert

Tell us the business, the markets and your timing. Every enquiry is answered the same business day, with a written proposal: the licence, the requirements, the cost and the timeline.

Your enquiry

Every enquiry is answered the same business day, with a written proposal.

HOW WE CAN HELP

What we do

A Senior Manager is personally accountable to the FCA for the areas set out in their Statement of Responsibilities, the document the FCA holds that lists what that person answers for. If a breach happens in their area, the FCA can take action against them personally where they did not take the steps a reasonable person in their position would have taken.

Most training covers the regime in general terms. People new to a Senior Management Function need something more specific: what each line of their own Statement of Responsibilities means in practice, which records will show they acted reasonably, and how the rules apply to the firm they are joining.

Our sessions are built on the firm's own documents and the individual's role, whether that is a partner at an LLP taking SMF27, a first-time compliance officer taking SMF16, an MLRO taking SMF17, or a board preparing for the changes proposed in CP26/37.

01

Document Review

We review the draft Statement of Responsibilities, the governance or responsibilities map and the relevant policies before the session.

02

Tailored Programme

We set the content around the individual's function, the firm's permissions and the risks of its business.

03

Session

A working session, one to one or with the board, in person or remotely, using the firm's own documents.

04

Record and Follow-Up

A written briefing pack, a training record for the firm's file and a follow-up session once the person is in the role.

DELIVERABLES

What's Included

Role-Specific Session

The function, its prescribed responsibilities and the individual's Statement of Responsibilities, line by line.

Conduct Rules and Duty of Responsibility

The Individual and Senior Manager Conduct Rules, the non-financial misconduct rules in force since 1 September 2026 and how the FCA assesses reasonable steps.

Reasonable Steps Evidence

The management information, minutes, escalation records and reviews that show the person acted reasonably in their area.

Briefing Pack

A written summary of the session, tailored to the role, for the individual to keep.

Training Record

A dated record of content and attendance for the firm's fitness and propriety file.

FCA Interview Preparation

Where the FCA asks to interview a candidate, preparation built on the firm's own application.

Who the training is for

SituationTypical functionFocus of the session
First Senior Management FunctionAny SMF, often SMF3 or SMF27Personal accountability, Statement of Responsibilities, reasonable steps
New compliance officer or MLROSMF16 or SMF17Oversight, monitoring, reporting to the board, financial crime duties
Partner at a partnership or LLPSMF27Individual accountability where decisions are taken collectively
Board or committee chairSMF9 to SMF14Challenge, information flow and committee records
Firm applying for authorisationAll proposed SMFsReadiness for the application and any FCA interview
WHO WE WORK WITH

Who this service is for

Firm types

  • - Investment firms, asset managers and partnerships
  • - Payment, e-money and cryptoasset firms
  • - Consumer credit lenders and brokers
  • - Insurers, MGAs and insurance intermediaries

Situations & Triggers

  • - A Senior Manager is being appointed for the first time
  • - A firm committed to a training plan in a Form A application
  • - A firm is applying for authorisation and expects an FCA interview
  • - A board is preparing for the CP26/37 changes
WHY REGULATORY COUNSEL

Why firms choose Regulatory Counsel

200+ licence and registration engagements

Applications taken through regulators in the United States, the United Kingdom, Europe, Canada, Australia, the Middle East and Asia.

Senior-led

The same senior practitioners run your engagement from the first assessment to the last regulator question.

Every regulated sector

Payment, e-money, money transmission, crypto, banking, lending, insurance, mortgage and investment firms.

In writing, the same day

Every enquiry is answered the same business day, and scope, timeline and fees are set out in writing before work begins.

Ready to get started?

Every enquiry is answered the same business day, with a written proposal.

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Frequently asked questions

The individual's function and Statement of Responsibilities, any prescribed responsibilities allocated to them, the Individual and Senior Manager Conduct Rules, the Duty of Responsibility, the records that evidence reasonable steps, and the risks specific to the firm's business. It closes with the changes proposed in CP26/37 and what they mean for the role.

Both. A new Senior Manager usually benefits most from a one-to-one session built on their own documents. Boards and senior teams can be trained together, with the session organised around the firm's responsibilities map.

Either. In person suits a one-to-one session that works through confidential documents. Remote delivery suits firms with Senior Managers in several locations.

Firms must ensure Senior Managers are competent for their role and, at present, must train staff on the Conduct Rules that apply to them. Where a candidate has not held a Senior Management Function before, firms commonly set out a training plan in the application. CP26/37 proposes replacing the statutory Conduct Rules training duty with a duty to notify staff of the rules, but competence remains the firm's responsibility.

Yes. The firm receives a dated training record of content and attendance for its fitness and propriety file, and the individual receives a written briefing pack.

Yes. Preparation is built on the firm's own application, business plan and the candidate's Statement of Responsibilities.