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The FCA SM&CR Deadline Extended – but don't overlook it

The FCA SM&CR Deadline Extended – but don't overlook it

Amongst all the pressures on dealers to get ready for the FCA changes to motor finance; one bright spot is that they now have an extension to comply with the Senior Manager Certification Regime SM&CR), which affects every dealer or dealer group. Scheduled to come into force on December 9th this has been delayed until March 31st. However, dealer compliance expert Tara Williams Group Chief Risk & Compliance Officer at AutoProtect Group and MD at i-Comply is urging dealers not to place SM&CR on the back-burner, noting;

"News that final SM&CR implementation will now come into force on March 31st is good news, with a recent survey highlighting that over 80 per cent of dealers were not fully ready for the new level of personal accountability. The extension provides a vital window to ensure SM&CR and the broader motor finance changes on pricing model and commission disclosure changes, which are dominating the finance agenda right now, are totally aligned because if they are not, somebody in the business will be personally accountable for any failures."

The personal accountability for a dealer's finance activities that is part and parcel of SM&CR will come into sharp focus in 2021 as a new era of transparency comes into force for motor finance from January 28th. While SM&CR implementation deadline is not until two months later, Williams is very clear that whoever holds SM&CR responsibility for a dealer or group, which is already in place but does not come into full effect until March 31st,  must ensure there is a total business-wide commitment to the changes ahead and these are likely to be significant as she closes;

"Having held SM&CR responsibility at a major dealer group, I'm very aware that creating not only the processes and control necessary for compliance but also the required cultural focus on delivering good customer outcomes, is unlikely to be a quick fix if it has not already started. With many dealers still finalising their approach to the new motor finance policy amidst concerns for some on the impact of making changes that the regulator has forecast will save car finance customers £165 million a year in interest costs, there is much to be done in what is still a limited timeframe."

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