The tone of the papers suggests that a fundamental reform of the Regime will be unlikely. By Rob Moulton, David Berman, Jonathan Ritson-Candler, and Charlotte Collins On 30 March 2023, the PRA and the FCA published a joint Discussion Paper (FCA DP23/3 and PRA DP1/23) seeking feedback on the Senior Managers and Certification Regime (SMCR). … Continue Reading
The case provides instructive practical examples of the “reasonable steps” companies can take according to the FCA and a reminder of the FCA’s cultural expectations of CEOs. By David Berman, Jonathan Ritson-Candler, and Sean Wells On 16 November 2022, the FCA issued a final notice (Final Notice) to the former CEO of Sonali Bank (UK) … Continue Reading
UK regulators are considering how they can strengthen the regime to enhance standards and reduce risk. By Nicola Higgs and Charlotte Collins On 3 December 2021, the FCA published a Consultation Paper (CP21/34) on changes to its rules regarding the Appointed Representatives (AR) regime. HM Treasury simultaneously published a Call for Evidence, seeking views on … Continue Reading
This annual publication outlines some of the primary focus areas in 2021 for UK-regulated financial services firms. Some of these topics are attracting attention because they are an emerging trend, or because they are at a key stage in the implementation cycle. Other topics are longstanding, but remain at the top of the PRA’s and … Continue Reading
The PRA has released a largely positive report, along with nine follow-up actions and recommendations on the SMCR for PRA-regulated firms. By Rob Moulton, Katy Sanders, and Anna Lewis-Martinez The PRA reviewed the operation of the Senior Managers and Certification Regime (SMCR) against its original objectives and examined whether there have been any unintended consequences. … Continue Reading
The FCA has provided updated guidance on the SMCR for solo-regulated firms, with new information on good and bad practices in two key areas. By David Berman and Anna Lewis-Martinez On 14 August 2020, the FCA updated its webpage on the Senior Managers and Certification Regime (SMCR) for solo-regulated firms. The updates include tables setting … Continue Reading
UK Regulators announce new measures after acknowledging firms affected by COVID-19 will need to keep their governance arrangements under review. By Rob Moulton and Anna Lewis-Martinez On 3 April 2020, the FCA and the PRA released a statement announcing several new governance measures for dual-regulated firms amid the COVID-19 outbreak under the Senior Managers and … Continue Reading
All firms should take note of the FCA’s latest feedback on SMCR implementation. By Rob Moulton, Charlotte Collins and David Berman In its latest piece of feedback on firms’ implementation of the SMCR, the FCA indicated that firms must improve their implementation of the Certification Regime and, most particularly, the Conduct Rules. While the FCA’s … Continue Reading
