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SM&CR – Regulatory References Requirements

By 5th May 2025No Comments

Since the 9th December 2019, firms are required to obtain a Regulatory Reference for any new Senior Managers (who will hold a FCA Senior Manager Function) or who will be registered as a Certified Person (also known as a Directory Person, such as a Mortgage Adviser) on the FCA Register. Regulatory References help ensure that firms are hiring individuals who are fit and proper for their roles, thereby strengthening accountability.

The FCA prescribes what must be included in a Regulatory Reference. This includes sharing details about any disciplinary actions, conduct rule breaches, or fitness and propriety issues over the past six years (or disclose any severe misconduct beyond that timeframe). Our downloadable template on the Ecompli website meets these FCA standards, simplifying the process for firms needing to request or provide Regulatory References.

For employees not on the FCA Register, a standard reference is sufficient, as they fall outside the scope of this requirement.