The Senior Managers and Certification Regime (SMCR) will apply to all authorised firms, including FCA authorised asset managers (Asset Managers) from 9 December 2019 (subject to certain transitional provisions). The specific requirements that will apply will depend on how the Asset Manager is categorised, i.e., whether as limited scope, core or enhanced.
Most Asset Managers will be core firms. Enhanced firms will be those seen as involving greater risk (if they have over £50 billion assets under management or qualify as CASS large firms). Limited scope firms include those authorised alternative investment funds which are internally managed.