Speaking to Jeremy Duncombe, director of intermediaries at Accord Mortgages on its latest Growth Series podcast, Lovell said many of the firms he had made contact with were yet to start working on preparing for the changes which come into force on 9 December.
He said: “Some have taken the time to sit around a table and hatch a plan and decide what to do. But we’ve got to bear in mind now, we’re just over four months away from the implementation date so firms need to sit up and take notice.”
He advised firms to “read up” on the requirements and recommended larger ones create a document or project team while suggesting that smaller firms look at templates online, read the Financial Conduct Authority (FCA) guide and use other online resources.
Lovell added: “What we believe is going to happen is the FCA will write to all firms and ask them what type of firm they are: limited firm; core firms and enhanced firms with 35m worth of intermediary income. That has an impact on what you have to do.”
For the Senior Management Regime, existing senior managers would be automatically converted onto the new regime and Lovell advised senior managers to create a statement of responsibilities, ready for inspection on 9 December.
The Certification Regime will be subject to qualification requirement and Lovell said it would hold senior managers accountable as it would be based on whether senior managers deemed certain individuals as “fit and proper”. Conduct rules will be applicable to all staff.
Lovell concluded: “Invent the right culture in your business as soon as possible.”