The FCA published an update last week confirming that it has been working closely with HM Treasury on preparing the Commencement Order needed to enable the FCA to publish the final rules on the extension of the SM&CR to solo-regulated firms, which are on track to come into force on 9 December 2019.  With less than six months to go, if not already started, firms should be taking steps to implement the new regime, which will involve a shift for most businesses, both structurally and culturally.  If you would like to know more about the new regime and what it means for your business, please contact me or Alan Hughes and Laura Autiero in our Retail Financial Services team.