SYSC 25.7 Guidance about SYSC 25 Annex 1G

This section gives guidance about SYSC 25 Annex 1G (Examples of the business activities and functions of an SMCR firm).

1. (1)

   A firm may use SYSC 25 Annex 1G as a prompt to see whether its management responsibilities map covers all its business activities.

2. (2)

   A firm may wish to prepare its management responsibilities map using the same split of activities, where this is appropriate.

As mentioned in SYSC 26.11.2G, a firm may also use SYSC 25 Annex 1G as a prompt when allocating responsibilities under SYSC 26 (Senior managers and certification regime: Overall and local responsibility).

If a firm uses SYSC 25 Annex 1G to help it prepare its management responsibilities map or when allocating responsibilities under SYSC 26 (Senior managers and certification regime: Overall and local responsibility), it should bear in mind that it is not comprehensive and that there may be other business activities and functions that are relevant to that firm but that are not included in SYSC 25 Annex 1G (see SYSC 25.7.8G).

The purpose of SYSC 25 Annex 1G is not say how an SMCR firm should:

1. (1)

   prepare its management responsibilities map;

2. (2)

   allocate responsibilities amongst its senior management; or

3. (3)

   organise itself.

SYSC 25 Annex 1G sets out examples of the business activities and functions that the FCA thinks could be relevant to most large or complex firms, although the FCA does not require firms (large or small, complex or non-complex) to organise themselves in this way.

Most or all of these activities and functions will normally apply to a complex firm. Many of them may not apply to a non-complex firm.

1. (1)

   SYSC 25 Annex 1G is not comprehensive. While it is intended to cover most front-line business activities of an SMCR firm, it does not cover all internal oversight and monitoring functions.

2. (2)

   For example, it does not cover compliance or internal audit or the firm’s governing body or its committees.