As we mentioned in our post on 04 August, the FCA and PRA propose to extend the SM&CR regime to all regulated firms, including insurers - both consultations are due to close on 03 November 2017.
This extension will bring most employees within the ambit of the two regulators’ enforceable conduct rules (conduct rules staff), not just senior management, so that they will be at risk of direct regulatory enforcement/fines. In addition, Senior Managers will be assessed for fitness and propriety and will need to be approved by the PRA/FCA. The biggest change for insurers, however, will be the Certification Regime; persons undertaking certified functions will need to be certified by the firm on at least an annual basis. following on from our client call on 04 August, please see our elexica article or contact Pollyanna Deane/Laura Allen for more detail.
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