Lloyd's Market Association Bulletin

LMA18-033-SM  |  05 July 2018

Senior Managers & Certification Regime guidance issued

***UPDATE 07 AUGUST 2018***

We have updated our guidance  to reflect the difference in approach between the PRA and FCA regarding Material Risk Takers (MRTs) and the Certification Regime (page 13 of the guidance). The FCA’s application is wider than the PRA’s - MRTs within all SII firms are in scope under the FCA’s rules, while only those within “large SII insurers” and “large NDFs” are in scope under the PRA’s rules. The FCA states that this is a deliberate distinction which reflects the different statutory objectives of the two regulators.

However, with respect to the scope of application to individuals, the FCA has confirmed that it is not looking beyond those who are subject to the SII remuneration requirements

[* The PRA defines large SII firms as those with annual premium income > £1bn or with assets related to regulated activities >£10bn.]


The PRA has published its final rules and the FCA has published its near final rules on the Senior Managers & Certification Regime.

The LMA has prepared guidance for managing agents on the new Senior Managers & Certification Regime (SM&CR). This comes into force on 10 December 2018, replacing the current Senior Insurance Managers Regime. The guidance seeks to provide managing agents with a consolidated, tailored overview of the new regime.

   LMA Guidance: Senior Managers & Certification Regime (SM&CR)


Also, the FCA has published a useful SM&CR Guide for Insurers and also Final Guidance on the Duty of Responsibility.

We would like to thank the LMA Regulatory Committee for their considerable input in assisting with the preparation of this guidance.

Steve Morrell
Head of Regulatory Affairs