Investigate SMCR Conduct Breaches With Confidence

When an allegation of misconduct arises, how you investigate matters. Poorly handled investigations create regulatory risk, employment disputes, and potential FCA scrutiny.

This comprehensive toolkit provides the structure, templates, and guidance to conduct fair, thorough, and compliant investigations every time.

WHAT'S INCLUDED

1. Individual Conduct Rules Guide

Detailed breakdown of Rules 1-5 with specific breach indicators and examples:

• Rule 1: Integrity — acting with honesty and trustworthiness

• Rule 2: Due Skill, Care and Diligence — competent performance

• Rule 3: Open and Cooperative — working with regulators

• Rule 4: Customer Interests — treating customers fairly

• Rule 5: Market Conduct — maintaining market integrity

2. Senior Manager Conduct Rules Guide

Complete coverage of the four additional rules for Senior Managers:

• SC1: Effective Business Control

• SC2: Regulatory Compliance

• SC3: Appropriate Delegation

• SC4: Disclosure to Regulators

3. 5-Stage Investigation Protocol

Structured process with clear timelines:

• Stage 1 (Days 1-3): Initial Assessment

• Stage 2 (Days 4-21): Evidence Gathering

• Stage 3 (Days 22-28): Subject Interview

• Stage 4 (Days 29-35): Analysis and Findings

• Stage 5 (Days 36-42): Report and Recommendations

4. Breach Assessment Matrix

Severity scoring framework covering:

• Intent (unintentional to deliberate)

• Impact (minimal to significant harm)

• Pattern (isolated to systemic)

• Seniority (junior to Senior Manager)

• Cooperation (full cooperation to obstructive)

5. Evidence Collection Checklist

30+ item checklist covering:

• Documentary evidence

• Transaction and activity records

• Communications (email, calls, messages)

• Customer-related evidence

• Witness evidence

• Regulatory and compliance records

6. Interview Templates

• Subject notification letter template

• Structured interview question framework

• Opening, background, core investigation, and closing questions

7. Outcome Determination Framework

Clear criteria for reaching findings:

• Substantiated

• Not Substantiated

• Inconclusive

8. Disciplinary Recommendation Guide

• Outcome matrix by severity (Low/Medium/High)

• Aggravating factors (increases severity)

• Mitigating factors (reduces severity)

9. FCA Notification Decision Framework

Clear guidance on regulatory notification requirements:

• When notification is mandatory (SUP 10C.14.18R, SYSC 25)

• Decision matrix by staff category

• 7 business day deadline guidance

10. Investigation Record Template

Comprehensive case documentation including:

• Case reference and subject details

• Allegation description

• Conduct rules potentially breached

• Finding and severity assessment

• Disciplinary action and FCA notification status

11. Timeline Tracker

Milestone-based progress monitoring to keep investigations on track.

12. Regulatory References

Key sources including COCON, SUP 10C, SYSC 25, EG, and DEPP.

WHO IS THIS FOR?

• Compliance Officers leading conduct investigations
• HR Directors managing disciplinary processes for regulated staff
• MLROs investigating Rule 1 and Rule 3 breaches
• Risk Managers assessing conduct risk
• Any firm subject to SMCR

FORMAT

20+ page PDF document (.pdf) with Templates copied in an additional Word (docx) ready to customise with your firm's branding. Use for unlimited investigations within your organisation.

WHY THIS TOOLKIT?

✓ FCA COCON compliant framework

✓ Covers all 9 Conduct Rules (Individual + Senior Manager)

✓ Clear notification guidance prevents missed deadlines

✓ Structured process ensures consistency

✓ Templates save hours of drafting time

✓ Comprehensive documentation protects your decisions

REGULATORY REFERENCES

• FCA COCON 2.1 — Individual Conduct Rules

• FCA COCON 2.2 — Senior Manager Conduct Rules

• FCA SUP 10C — Senior Managers Regime

• FCA SYSC 25 — Breach Reporting

• FCA Enforcement Guide (EG) Chapter 7

INSTANT DOWNLOAD

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Compliance Consultant — Making Compliance Work

https://complianceconsultant.org

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