On 28 September 2016, the Financial Conduct Authority (FCA) marked six months since the implementation of the Senior Managers and Certification Regime by providing feedback on its implementation so far and proposing measures to further strengthen the regime.

The new measures are part of the FCA’s continued focus on culture, and build on initiatives to further empower it to identify and hold senior individuals in banking and insurance firms to account.

This COMSURE alert will HIGHLIGHT the significant impact on the relevant firms and individuals that results from the following FCA publications:

1. FCA Consultation Paper (CP16/26), Guidance on the duty of responsibility: amendments to the Decision Procedure and Penalties Manual;

a. CP16/26

2. FCA Consultation Paper (CP16/27), Applying out conduct rules to all non-executive directors in the banking and insurance sectors;

a. CP16/27

3. FCA Policy Statement (PS16/22), Strengthening accountability in banking and insurance: regulatory references final rules;

a. PS16/22

4. FCA Discussion Paper (DP16/4), Overall responsibility and the legal function;

a. DP16/4

5. Supervisory review of statement of responsibilities and responsibilities maps contained in four Feedback Statements (FS16/6, FS16/7, FS16/8, and FS16/9);

a. FS16/6
b. FS16/7
c. FS16/8
d. FS16/9

6. FCA Consultation Paper (CP16/25), Whistleblowing in UK branches of overseas banks; and

a. CP16/25

8. FCA Consultation Paper (CP16/28), Remuneration in CRD IV firms: new guidance and changes to Handbook.

a. CP16/28