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1 SMF/CR Due Diligence Checklist

AUDIT TYPE:                      INITIAL/ANNUAL/SPOT CHECK

DATE:                                  ________________­

 NAME OF AUDITOR:   _________________________

AUTHORISED BY:        ________________­­­­_________
1. SMF/CF ROLES
ASSESSMENT QUESTION YES NO AUDITORS NOTES
Have you defined your SM&CR tier? (i.e. Core, Enhanced or Limited Scope)
Have you documented who your Senior Managers are and the SMF role performed?
Have you ensured that every activity, business area and management function have a Senior Manager who has been allocated overall responsibility for it?
Have you assessed which SMF/CF roles may require access to systems for submissions and allocated the relevant access and logins? (i.e. GABRIEL, CONNECT etc)
Is it clear via your organisation chart or associated document who has each of the SMF responsibilities?
Does each Senior Manager have a completed Statement of Responsibilities (SoR)?
Have you submitted a copy of each SoR to the FCA for approval?
Have you defined which Certification Functions apply to the Company?
Have you identified the individuals within the Company who need to be certified?
ASSESSMENT QUESTION YES NO AUDITORS NOTES
Have you identified which Prescribed Responsibilities (PRs) apply to the Company?
Have you fully assessed all Prescribed Responsibilities (PRs) to ensure that they are allocated to a Senior Manager based on suitability and relevance?
Have you created a Responsibilities Map in accordance with SYSC 25? (enhanced firms only)
Have you created Handover Procedures and included them in your SMF Handover Policy?
If you are converting to SM&CR, have you reviewed you existing approvals to SMF roles and ensured that any new ones are appointed?
2. FIT & PROPER ASSESSMENTS
Have you completed SMF/CF Due Diligence Questionnaires for all individuals being appointed to a SMF/CF role?
Have you collected evidence to support background checks, qualification certificates, training (previous & ongoing) and general suitability for each individual performing a SMF/CF role?
Are regulatory references always obtained for individuals applying for a SMF/CF role where they are not an existing employee?
Where references have been obtained, do they cover the past 6 years of employment?
ASSESSMENT QUESTION YES NO AUDITORS NOTES
Do you keep records of F&P tests, complaints, training and qualifications for each individual holding a SMF/CF role to ensure that you provide a valid reference should they apply for a similar role elsewhere?
Has each SMF/CF individual’s honesty, integrity & reputation been assessed via references, background checks, interviews and supporting evidence?
Has the financial soundness of each SMF/CF individual been assessed through credit checks and background assessments?
Has the competence and capability of any individual appointed to a SMF/CF role been assessed through qualifications, training and past experience?
Have the relevant FCA training and competence requirements been reviewed to ensure that those holding SMF/CF roles meet those requirements? (or are schedule to complete the relevant training if applicable)
Have you implemented HR processes to ensure that F&P tests and background checks are carried out on an annual basis?
3. SMF ROLE(s) ONLY
Have you completed CRB checks for all individuals performing a SMF role?
Do you have a process for reviewing CRB checks annually for SMF roles?
Have you revised your HR procedures to include annual fit & proper assessments and background check reviews?
ASSESSMENT QUESTION YES NO AUDITORS NOTES
If an individual being appointed to a SMF role has not been resident in the UK prior to application, have you obtained the CRB check equivalent from the relevant country? (where applicable?)
Have you ensured that FCA approval has been obtained for all SMF appointed individuals prior to them undertaking the role?
Have you submitted an SoR to the FCA for each appointed individual? (where applicable)
4. CERTIFICATION FUNCTION(S) ONLY
Have individuals performing CF roles been verified as possessing one or more qualifications relevant to the function being performed?
Have individuals performing CF roles been assessed and verified as having been through (or are currently attending) training applicable to the CF function being performed?
Has the competence of those performing a CF position been assessed and evidenced?
Have you completed a Due Diligence Questionnaire for each individual performing a CF that supports the required criteria for the role?
Where a CF role is being filled by an external candidate (not a current employee), have you verified and gained evidence of any qualifications, training and competency as it relates to the CF role?
ASSESSMENT QUESTION YES NO AUDITORS NOTES
Where an individual is to perform more than one Certification Function, have you ensured that they have been assessed against the requirements of each function?
Have Certification Function Certificate been issued to those performing CF roles?
If yes to the above, does each certificate:

  • State that the authorised person is satisfied that the person is a fit and proper person to perform the Certification Function?
  • Set out the aspects of the Company’s business in which the individual will be involved?
5. CONDUCT RULES
Has a Senior Manager been allocated a PR for ensuring that the relevant employees are aware of, and are trained on the Conduct Rules?
Have you implemented a training program covering the Conduct Rules and assigned the session to the relevant employees?
Do you have robust and adequate breach procedures in place for any employee breaching the conduct rules?
Do you have procedures for reporting breaches of the conduct rules to the FCA?
Do you have a procedure for submitting the annual notification about Conduct rules (even if there have not been any breaches)?
AUDITOR DECLARATION

Once completed, the auditor should complete the below section and gain Director/High Level Management sign off. A copy of the completed sheet should be retained for 5 years after the review date & should be saved in date format to enable cross-referencing & progress reporting.

 

AUDITOR                                                                   SENIOR MANAGER

Signed:            _______________________              Signed:            _______________________

 

Print:               _______________________              Print:               _______________________

 

Date:               _______________________              Date:               _______________________