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Timeline & What has Changed?

Timeline & What has Changed


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Full video transcript available below:

Welcome and thank you for joining today's webinar hosted by me, Joe Boyhan of MyComplianceOffice, and Gregory Brandman and Simon Collins of Eversheds Sutherland.

I'm going to hand it over to Simon now to talk you a little bit through the timelines that have occurred to date and the approach to implementation and going forward to the rest of the industry.

Thank you, Greg, and good afternoon ladies and gentlemen. We put this slide in because it just does demonstrate the journey that the banks and the building societies, insurance firms actually went on it. Importantly as well, the fact that there was a transitional period. If you look, you'll see that the regime commenced on the 7th of March 2016, but there was a year in which individuals needed to be certified. Now, I come back to what that has meant in due course, and also that then conduct rules, which Greg will touch on, coming for every individual within the firm.

In addition, and I think importantly, there has been ancillary information and consultation requirements running alongside, such as the whistleblowing rules that have become active as well since September 2016, the regulatory references, and we're going to touch on a few of these things in due course. We're still waiting though for some further information. Notably, whether or not the legal function will form part of the senior managers regime, it is understood that there will be a further consultation in quarter three on that actual situation as to whether or not legal functions will be caught. Quite a lot of interest obviously around general councils on that basis.

Then in respect, the extension proposal, that is now changed. It was going to be June, and now it's being referred to as "summer". In conversations with the FCA, there does seem to be clarity that it is the summer, not when individuals think the summer ends and autumn starts. It's possibly debatable, but I think the money seems to be on some time in late August as the likely date's subject to any other alteration, which of course has had an impact.

Bearing in mind, originally we were supposed to see this consultation in January of this year. That may also have an impact on the implementation of the extended regime as well. Albeit, it is still being talked about as 2018 and therefore firms do need to be considering the impact of that is going to have on them now actually, not necessarily waiting to far down the track.

If we could turn to the next slide, please. I'll then just talk a little bit more about what has changed. I do, this particular area, that sort of three limbs of the regime, where you go off the senior managers. I'm going to touch on those in a bit more detail, but they are pre-approved by their regulators, a new certificate regime, where the [inaudible 00:11:54] is on the firm to actually assess whether or not certified individuals are fit and proper.

Then the new conduct rules as well, which then come into play for other staff. In fact, there is some specific rules there for senior managers, which Greg will touch on. The next slide, please, if I may.

 

This webinar was co-hosted with Eversheds-Sutherland

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