Contents
Record of Minutes
Regulator Information Requests
Regulatory Remediations
Employment History (T)
Summary of responsibilities
Senior management functions
Prescribed responsibilities
Overall responsibilities
Other responsibilities
Supplementary information
Certification functions
FCA Directory Information
Gifts and hospitality register
Personal account dealing
Summary of responsibilities
Senior management functions
Prescribed responsibilities
Overall responsibilities
Other responsibilities
Supplementary information
Record of Minutes
Boards and Committees details (T)
Senior Manager responsibilities (T)
Handover procedures
Handover notes
Responsibilities handed over (T)
Summary of handover issues (T)
Outsourced functions
Criticality assessment
Risk assessment
KPIs
Issues log
Access rights
Sub-contracting
Termination rights
Outsourcer risk assessment
Reasonable steps' framework
Senior Manager Decisions Record (T)
Regulatory reference tracking
Incoming communications (T)
Outgoing communications (T)
Additional information requests
Outgoing reference revisions (T)
Reference subject communication attempts (T)
Reference subject comments (outgoing references) (T)
Firm(s) providing regulatory references (T)
Employment history (T)
Conclusions and hiring decision (T)
Incoming reference revisions (T)
Reference subject comments (incoming references) (T)
Purpose of assessment
Information completeness
Sources of Info - Honesty and Integrity
Sources of Info - Competence and capability
Sources of Info - Financial soundness
Expected date and type of next review
Civil Proceedings
Complaints
Criminal Proceedings
Disciplinary Proceedings and Conduct Rules Breaches
Register of Directorships and Positions of Trust
Regulatory matters
Qualifications
Performance Reviews
Training Record
Professional Bodies (T)
Financial Advisors
Certificate level subjects
Diploma level subjects
Advanced diploma level subjects
IFS DipFA
Other Qualifications
Permitted Areas of Advice
Financial Soundness Assessment
Assets
Liabilities
Income
Expenditure
Civil Proceedings
Disciplinary Proceedings and Conduct Rules Breaches
Training Record
Admin
Administrators are users of Corterum who have access to everything within the system. This includes, but is not limited to:
The ability to create and manage User accounts.
The ability to set tasks for User accounts.
Manage and customise workflow rules within your instance of Corterum.
The Firm
Under SM&CR, you must hold and be able to report to the FCA on demand several pieces of general, financial, and regulatory information about your firm. Corterum helps you to store this in the format and to the extent required by the FCA.
SM&CR Classification
Under the Senior Manager & Certification regime, all firms subject to the regime are defined as belonging to one of three classifications: Limited scope, Core or Enhanced.
Regulated Activities
The activities that the FCA regulates that are carried out by your firm.
Boards and committees
SM&CR has a strong emphasis on appointing the most fit & proper persons to corporate governance committees. Furthermore, the chair of some committees (e.g. the audit committee and the nomination committee) is a Senior Manager under the regime.
Record of Minutes
A record of minutes for any meetings undertaken on any boards or committees.
Regulators
This typically refers to the Financial Conduct Authority (the FCA), the primary regulator for many of the actions undertaken by financial services firms.
Regulator Information Requests
A record of all historic regulatory information requests made for an individual.
Regulatory Remediations
If an organisation has any gaps in their SM&CR compliance processes, this requires steps to be taken in order to remediate these gaps.
Staff
Staff members are Corterum users who do not possess administrator access. Their ability to use the system can be limited in a number of ways by admin users.
Staff Information
Refers to personal details, Senior Management Functions, responsibilities (prescribed, overall and other); as well as certifications.
Employment History (T)
A record of an individual's history of employment that is relevant to their current role, including the following information:
Name of employer
Dates of employment
Nature of employment (e.g. employee)
Position held within the company
Responsibilities
Salary
Reason for leaving
Summary of responsibilities
A summary of all prescribed, overall and other responsibilities that have been delegated to an individual, including the following information:
Summary of responsibility
Details of responsibility
Information regarding shared responsibilities (if applicable)
Job title
Individual Reference Number
Senior management functions
A senior management function is defined as a regulated activity by an authorised person, if (a) the function will require the person performing it to be responsible for managing one or more aspects of the authorised person’s affairs, so far as relating to the activity, and (b) those aspects involve, or might involve, a risk of serious consequences (i) for the authorised person, or (ii) for business or other interests in the United Kingdom.
Prescribed responsibilities
These are the responsibilities that the FCA mandates firms to share amongst their Senior Managers, including the following information:
Type of responsibility prescribed
Effective date
Information regarding shared responsibilities (if applicable)
Individual Reference Number
Overall responsibilities
This is the term used by the FCA to describe when a Senior Manager heads and controls a business function or activity that could cause significant harm to the firm or potentially to the wider financial system, including the following information:
Overall responsibility title
Overall responsibility description/details
Distinction from other overall responsibilities
Information regarding shared responsibilities (if applicable)
Job title
Individual Reference Number
Other responsibilities
Other Responsibilities (Optional).These are any significant responsibilities held by the SM that are not accounted for in the ‘Summary of Responsibilities’, ‘Prescribed Responsibilities’ or ‘Overall Responsibilities’ The FCA mandates that each ‘Other Responsibility’ must be described in 300 words or less.
Supplementary information
Any other information relevant to an individual's role and assigned responsibilities.
Certification functions
A register of all certification functions assigned to an individual, including:
Certification function (e.g. Significant Management)
Effective date
End date
Date of last Fit and Proper certificate and an upload of the certificate document
FCA Directory Information
Register of FCA directory information, including the following:
Certification function
Role start date
Role end date
Customer engagement method
Activities undertaken
Work locations
Gifts and hospitality register
A register of all gifts and hospitality received by an individual, including the following information:
Date of declaration of the gift/hospitality
Date gift/hospitality received
Type of gift or hospitality
Description
Action taken (whether it was accepted or rejected)
Contact details and relationship to the provider of the gift/hospitality
Personal account dealing
A record of any account dealings such as stock purchases, including the following information:
Date of purchase
Name of security purchased
Symbol/stock code (e.g. GME)
Number of shares purchased
Nature of transaction (e.g. purchase)
SM&CR
Senior Managers and Certification Regime - The overarching set of regulations which must be followed by all those working in financial services firms.
Senior Managers Regime
The regulations applicable to top tier management within a firm, otherwise referred to as Senior Managers.
Statement of Responsibilities
The FCA describes a statement of responsibilities as @a statement setting out the aspects of the affairs of the firm which it is intended that the person will be responsible for managing in performing the function.@
Summary of responsibilities
Add description
Senior management functions
A function that has been designated by the FCA as a designated senior management function. Senior management functions include, but are not limited to:
Anyone who performs an SMF needs to be approved by the FCA before they can start their role.
Prescribed responsibilities
Responsibilities specifically prescribed by the FCA to senior managers.
Overall responsibilities
Add description
Other responsibilities
Any additional responsibilities required to be fulfilled
Supplementary information
Any additional information to supplement the responsibilities assigned to a particular member of staff.
Boards and committees
SM&CR has a strong emphasis on appointing the most fit & proper persons to corporate governance committees. Furthermore, the chair of some committees (e.g. the audit committee and the nomination committee) is a Senior Manager under the regime.
Record of Minutes
A record of minutes taken for any board/committee meeting.
Management Responsibilities Map
For enhanced format he FCA required you to complete a map of Management Responsibilities with give a close look at the structure of the firm, its board and functions.
Boards and Committees details (T)
A record of the membership, structure and remit of boards and committees in Corterum.
Senior Manager responsibilities (T)
A full list of responsibilities assigned to a Senior Manager.
Handovers
Under SM&CR, whenever another Senior Manager takes responsibility for a particular Senior Manger function - whether on a temporary or permanent basis, a handover must be completed so any issues or data are available to the Senior Manager's replacement.
Handover procedures
The procedures which must be followed in order to properly hand over responsibilities to a third party.
Handover notes
Any relevant notes left as part of the process of handing over responsibilities to a third party.
Responsibilities handed over (T)
A list of all functions handed over to third parties to be carried out.
Summary of handover issues (T)
Summary of all pertinent functions handed over to third parties to be carried out as well as the reasons for these functions being handed over.
Outsourcing
Ocassionally, Senior Manager functions or other core responsibilities need to be outsourced to a third party.
Outsourced functions
Any details of the functions that you have assigned to be carried out by a third party.
Criticality assessment
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Risk assessment
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KPIs
Key performance indicators (KPIs) refer to a set of quantifiable measurements used to gauge an individual's ability to adhere to the requirements of thje conduct rules.
Issues log
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Outsourcing contracts
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Access rights
Administrators of Corterum can allow or prohibit access to
Sub-contracting
Add description
Termination rights
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Outsourcer due diligence
The checks performed on any third party firms and individuals who handle functions on your behalf.
Outsourcer risk assessment
A record of any risk's identified by a third party outsourcer.
Senior Manager 'reasonable steps'
As part of complying with the SM&CR, Senior Managers have to confirm and outline the 'reasonable steps' they have taken to comply with the conduct rules that apply to them.
Reasonable steps' framework
The steps taken by an Enhanced firm to ensure a Senior Manager has all of the necessary resources and materials in order to do their job effectively.
Senior Manager Decisions Record (T)
Add description
Certification Regime
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Regulatory References
The framework of information sharing provided for under the SMCR to help firms avoid recruiting people with a history of poor conduct into senior roles and other positions where they have the potential to do significant harm to the firm or its customers.
Regulatory reference tracking
A complete record of any regulatory reference request for all relevant individuals.
Incoming communications (T)
A record of any incoming regulatory reference communications regarding a individual.
Outgoing communications (T)
A record of any outgoing regulatory reference communications regarding a individual.
Regulatory references provided
A record of all regulatory references provided for an individual.
Additional information requests
Add description
Outgoing reference revisions (T)
Add description
Reference subject communication attempts (T)
The number of times attempts have been made to contact to contact an individual's referees.
Reference subject comments (outgoing references) (T)
Any comments and additional information related to reference requests.
Regulatory references obtained
A record of all regulatory references obtained for one individual.
Firm(s) providing regulatory references (T)
A full list of all of the firms providing regulatory references.
Employment history (T)
A full history of an individual's history of employment relevant to their current role.
Conclusions and hiring decision (T)
Conclusions based on the results of regulatory references received as well as the decision to hire an individual or not.
Incoming reference revisions (T)
Add description
Reference subject comments (incoming references) (T)
Add description
Fit and Proper Testing
it's a benchmark used to assess whether you are suitable to perform a controlled function. Those standards also apply when FCA Approved Persons get re-assessed.
Fitness and Propriety Assessment Record
A record of an individual's current and previous fitness and propriety assessments.
Purpose of assessment
A description of the reason(s) why a fitness and propriety assessment has been completed.
Information completeness
Add description
Sources of Info - Honesty and Integrity
Add description
Sources of Info - Competence and capability
Add description
Sources of Info - Financial soundness
Add description
Expected date and type of next review
Add description
Fit and proper assessment criteria
The criteria used to determine an individual's fitness and propriety to carry out their functions within a firm.
Honesty, integrity and reputation
Add description
Civil Proceedings
Any civil proceedings that an individual has been involved with in the past.
Complaints
A record of any complaints which have been raised against a regulated individual.
Criminal Proceedings
An indication that an individual is involved in or has been involved in criminal proceedings.
Disciplinary Proceedings and Conduct Rules Breaches
Information about an individual's involvement with disciplinary proceedings by their employer or an appropriate regulator or any instances of them contravening the conduct rules.
Register of Directorships and Positions of Trust
Disclosure of all Director roles held by an individual as well as any positions held within Trusts.
Regulatory matters
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Competence and capability
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Qualifications
All of the required qualifications held by an individual which are relevant to their role.
Performance Reviews
A record of each time an individual's performance has been reviewed by a superior.
Training Record
A record of all training undertaken by an individual.
Professional Bodies (T)
Add description
Financial Advisors
Add description
Adviser Qualifications
Add description
Certificate level subjects
Add description
Diploma level subjects
Add description
Advanced diploma level subjects
Add description
IFS DipFA
Add description
Other Qualifications
Any other relevant qualifications which don't fit into the categorisations of 'Certificate level subjects', 'Diploma level subjects' or 'Advanced diploma level subjects.
Permitted Areas of Advice
Areas in which an adviser is permitted to offer legal advice due to them have the relevant qualifications and competencies.
Financial soundness
An assessment of numerous considerations regarding someone's financial soundness, and whether this will effect their ability to carry out their functions within a firm.
Financial Soundness Assessment
The conclusion of an individual's Financial Soundness Assessment.
Assets
A declaration of any relevant assets held by a regulated individual.
Liabilities
Add description
Income
Add description
Expenditure
Add description
Civil Proceedings
Add description
Conduct Rules
The standards of conduct set out by the FCA that almost all individuals working in financial services firms are held to.
Disciplinary Proceedings and Conduct Rules Breaches
Add description
Training Record
A record of all training received and completed by an individual which is relevant to their role.