The FSMA (Relevant Authorised Persons) Order 2015 came into force on 9 November. It provides that persons falling within either of two categories of non-UK institution are “relevant authorised persons” for the purposes of Part 5 of FSMA and the Financial Services (Banking Reform) Act 2013 (Transitional and Savings Provisions) Order 2015, and so fall within the scope of the Senior Manager Regime (SMR). The first category is non-UK institutions that are credit institutions and that have a branch in the UK, are authorised to accept deposits in the UK and are not insurers. The second category is those non-UK institutions that are investment firms that have a branch in the UK, are authorised to deal in investments as principal in the UK, are regulated by PRA in relation to that activity and are not insurers. (Source:SI2015/1865 – FSMA Relevant Authorised Persons Order)