Clifford Chance
A practical guide to the Senior Managers and Certification Regimes - October 2014
1 October 2014
At 395 pages, the joint consultation paper on individual accountability in the banking sector, published by the Financial Conduct Authority ("FCA") and the Prudential Regulation Authority ("PRA"), is weightier than the average guide to the galaxy.
Although some elements of the proposals may yet change in the light of responses to the consultation exercise, and as the regulators continue to refine their policy positions, the paper gives the clearest indications yet of the FCA's and PRA's (sometimes divergent) interpretations of how the new regimes set out in the Financial Services (Banking Reform) Act 2013 should work in practice, and to which firms and individuals it is proposed they will apply.
This briefing unpacks the main implications of the proposed new regimes and looks at the steps banks, building societies, credit unions and PRA regulated investment firms can take at this stage to map out their response to the proposals and begin to adjust their governance arrangements.
