How likely is it that any given SMF holder is under FCA investigation? Only about 0.02%

The number of open FCA investigations into Senior Management Function (SMF) holders is growing, as you might expect.

But does that tell the whole story?  As a proportion of all SMFs held, the number of open FCA investigations into SMFs has actually declined substantially before stabilising at about 0.02%.

Now, the pre-2020 statistics might more fairly represent the risk to SMFs at larger firms, before the SMCR was extended to most firms in late 2019.  Still, it's worth bearing them in mind when next you hear FCA public messaging about individual accountability.  The proportion of SMFs subject to investigation at any given time is small across the board, with the FCA relying primarily on firms themselves to embed senior managerial accountability within firms' organisation and culture.  Perhaps, then, the greatest enforcement risk from SMCR is faced not by individuals but instead by firms themselves.