The New Individual Responsibility Regime - Extending it across the Financial Services Industry

03 August 2017 Download PDF

On 26 July 2017, the FCA published consultation paper CP17/25 on the extension of the Senior Managers and Certification Regime (see our earlier report, which summarises the key proposals here).

Our brochure looks at each of the key elements of the new regime, assessing how they will apply to non-banking firms. With its proposals, the FCA has built on how the new regime has been implemented with banks, but has included several new elements that take into account proportionality, which will benefit smaller or simpler firms and impose additional requirements on those firms that are the largest and most complex.

We review in turn:

1. The basic structure
2. The designated senior management functions
3. Allocation of responsibilities to senior managers
4. Statement of responsibilities for senior managers
5. Management responsibility maps
6. The conduct rules
7. References
8. The certification regime
9. The duty of responsibility for senior managers
10. Application to UK branches of EEA and third country firms

Our brochure is available to download here

Should you require implementation support or wish to discuss the contents of this publication, please do not hesitate to contact us.

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Future Dates

* Estimated date

  • *31 October 2019

    Exit date is:

    •  31 October 2019 if the UK holds European Elections, but UK Parliament has not ratified the WA before that date; or
    •  The 1st day of the month after ratification if UK Parliament ratifies the WA before October 2019.

  • 1 December 2019

    End of four-year transitional period for RTS on risk-mitigation techniques for OTC derivatives contracts not cleared by a CCP under EMIR.

  • 31 December 2019

    Following PRA's policy statement (PS10/17) - operational continuity firms are expected to submit the template (PRA109) 45 business days after the first reporting period ending 31 December.