Navigating SMF1 Responsibilities: Leading a Firm Under the FCA Regime

Introduction

The Chief Executive function (SMF1) is the most senior executive position within SMCR. The inherent responsibility for the conduct of the whole business is clear. The SMF1 holder cannot escape accountability for any aspect of the firm through delegation.

It is widely known that the FCA will hold CEOs personally accountable for significant breaches, poor culture, and governance failures within their business. The Duty of Responsibility creates a high bar. You must demonstrate reasonable steps to prevent breaches across all areas of the firm.

This session provides practical guidance for current SMF1 holders and those expecting to take the function. You will gain clarity on defining and documenting your responsibilities, what reasonable steps looks like in practice, and how to navigate the relationship between collective board accountability and individual SMCR obligations.

What You Will Learn

This live and interactive course will cover the following:

• The SMF1 Mandate
• What responsibility for the whole business means in practice
• Why delegation does not reduce CEO accountability
• Best practice for your Statement of Responsibilities
• The higher standard for CEO reasonable steps
• Culture and Conduct
• Why CEOs are personally accountable for firm culture
• Non-financial misconduct and setting tone from the top
• Consumer Duty (where relevant) and ultimate accountability for out-comes
• Governance and Managing Senior Managers
• The CEO and Board relationship and accountability boundaries
• Overseeing other Senior Managers
• Appointing and allocating responsibilities under SMCR
• Strategic Risk and Controls
• Setting and monitoring risk appetite across three lines of defence
• Financial crime, operational resilience, and prudential oversight
• Emerging risks
• Regulatory Relationships and Enforcement
• Building an effective FCA relationship and knowing when to engage
• Enforcement, personal liability, and recent CEO cases
• Exit planning and successor transition

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.