I've mentioned the certification regime. This applies to any individual who could cause significant harm to the firm or its customers. Typically, these individuals are those that require a qualification to undertake their role. As an example, the current CS30 control function, 30 for investment advisors, is called by the definition of significant harm, because what will happen and has happened for the banks and building societies is they no longer have CS30s registered with the FCA. It is up to the firm themselves to assess those individuals and deem them to be demonstrably fit and proper.

What this has meant is this particular area has required firms to look again at their onboarding process, their referencing process there over all assessments and appraisal processes in order to give themselves comfort that they're approaching this particular part of their regime with enough rigor. Over the course of the last 18 months, we've certainly found this is an area which has created a lot of challenge for firms initially identifying who those certified individuals are. Then the necessary steps to take to enhance the firm's appraisal process. It's fitting proper linking it into training and competence where appropriate.

Importantly, there is a senior manager who is designated to oversee the regime and that's certainly concentrated the mind of those senior managers to ensure that the regime is being adopted appropriately. Needless to say, that is why it has probably taken quite some considerable time for firms to really pull together their approach to certification.

This webinar was co-hosted with Eversheds-Sutherland