Conduct, Data & Competence – What’s Happening?

Julie Pardy

Julie Pardy

With more than 30 years service in the Financial Services industry Julie has spent many years at the coal face undertaking a wide variety of roles in banking from Compliance to Sales, Operations to Training.

Certification, Conduct Rules Training, Directory Data and Conduct Rules Breach Reporting; are you ready and prepared?

It was refreshing to see the FCA act true to their word when at the start of the pandemic they stated that where they could, they would exercise “Regulatory Flexibility.” With the recent announcements around Certification, Conduct Rules and Directory data, we heard a collective sigh of relief from many firms.

Regulatory flexibility-2

Really, some might say, firms have had long enough to work through the requirements! Well, maybe so, but many firms we have been working with and talking too are still finding quite a high level of disruption from current working practices and have greeted the recent proposed delays with open arms.

For those that might not have the full detail on the (proposed changes) here goes.

Certification – HM Treasury have announced that they will be amending legislation to allow for a delay in the first round of certification for solo regulated firms from the 9th December 2020 to the 31st March 2021.

Conduct Rules Training – Firms were required to ensure that all staff were trained in “role relevant” conduct rules by the 9th December 2020. A consultation from the FCA has recently closed after a short period of debate which proposes delaying the deadline to the 31st March 2021.

Directory Data – Firms were required to have submitted the wide-ranging requirements in respect of Directory Data to the FCA by the 9th December 2019. As per conduct rules, we await the results of the consultation which proposes delaying the deadlines and implementation period to the 31st March 2021.

Whilst at the time of writing this blog (Aug 20), the final policy statement confirming the delays on these last 2 points has not been published, but I can confidently say that it is very unlikely that March will not become the new deadline.


As observers of activity within Financial Services it has become clear to us over time that the volume of regulatory change announcements is overwhelming for many firms (especially so for those with limited resources). And to be honest, that’s exactly the kind of thing that we’re helping firms work through every day; alleviating the burden of regulatory change, deploying policy changes and simplifying the procedures that apply to you and your sector.

We are widely recognised as one of the foremost RegTech firms and leading authorities in the regulator change field, especially regarding SM&CR and how that applies to both dual regulated firms and solo regulated firms. Years of working knowledge and experience have been funnelled into both our SM&CR software solutions and our related consultative support.

If you believe you could benefit from improvements, wish to discuss mitigating risk, rationalising your records or de-risking your processes, give us a call and talk to a member of our team today, you might be surprised at how affordable and effective our help can be.

Our latest SM&CR Infographic provides an overview of the key elements of SM&CR and provides valuable information on how Worksmart’s purpose built SM&CR management system, Accord, provides solutions to the challenges posed by each of SM&CR’s elements.

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