It is difficult to know what to write about this that has not already been written. Advisers know that this regime is due to be implemented by 9th December 2019, but probably not many advisers have actually done anything about it. For many small firms, there may not appear to be much to do, but advisers underestimate the work involved at their own risk.

SM&CR is a catalyst for change – an opportunity to establish healthy cultures and effective governance in firms by encouraging greater individual accountability and setting a new standard of personal conduct.