On March 20, the UK’s Financial Conduct Authority (FCA) and the UK’s Prudential Regulatory Authority (PRA) separately published guidance on steps for firms to take to identify key workers in the financial services industry (as, exceptionally during this crisis period while schools are closed, the children of such key workers may continue to attend UK schools).
Continue Reading FCA and PRA Publish Guidance on Key Financial Workers Critical to COVID-19 Response

On November 29, the UK’s Financial Conduct Authority (FCA) published a consultation paper on applying the Senior Managers Regime (SMR) to benchmark administrators. (For more information on the Senior Managers and Certification Regime, or SM&CR, please see the July 28, 2017 edition of the Corporate & Financial Weekly Digest.)

SM&CR already applies to banks and insurers, and will apply to most other UK financial services firms as of December 9. Because benchmark administrators only began to be supervised by the FCA in January 2018, the SMR will apply to them starting December 7, 2020. This gives these firms one extra year to prepare for the regime.
Continue Reading SM&CR to Apply to Benchmark Administrators

On January 23, the UK Financial Conduct Authority (FCA), published a consultation paper on optimizing the senior managers and certification regime (SM&CR) (for further details on the SM&CR, see the March 11, 2016 edition of the Corporate & Financial Weekly Digest). Its proposals intend to help firms adjust to the SM&CR and to identify some of the rules which need to be revised, as currently drafted in the Individual Accountability (Amendment) (No 1) Instrument 2019.
Continue Reading FCA Consults on Optimizing the SM&CR and Proposes Excluding Heads of Legal From Senior Managers Regime

The UK Financial Conduct Authority (FCA) has published a document setting out its intention to self-apply the principles of the Senior Managers Regime (SMR) to strengthen transparency and “reinforce the standards,” noting that certain differences in the application of the principles are inevitable due to the FCA’s status as a regulatory authority and public body, rather than a regulated firm. However, the document also notes that the FCA will not be implementing the Certification Regime, which, when included with the application of the SMR, is included in the wider regulatory framework of the Senior Managers and Certification Regime (SMCR).
Continue Reading FCA Adopts Senior Managers Regime for Its Own Senior Management

On October 3, the UK Financial Conduct Authority (FCA) published a discussion paper (Discussion Paper) on the application of the UK Senior Managers Regime (SMR) to persons responsible for the legal function of a UK regulated firm.
Continue Reading FCA Publishes Discussion Paper on Firms’ Legal Function Under the Senior Managers Regime