Action list: Certification regime
It is proposed that the Certification Regime which has been introduced for banks will be extended to all FCA solo-regulated firms. The final rules are expected in a Policy Statement in Summer 2018 and are envisaged to apply to FCA solo-regulated firms from mid-to-late 2019.
This document summarises the steps which in-scope firms are likely to need to take in order to comply with the regime. To promote internal discussion and planning around these changes, this document summarises some of the steps which we anticipate will be required in relation to the three new aspects of the Certification Regime.
Implementation of the new Certification Regime - action points:
- Identify material risk takers (PRA) and functions described by FCA rules, including identifying business areas and divisions against the financial thresholds.
- Ensure that process is put in place to update these assessments on an appropriate basis, at least annually.
- Establish processes for annual assessment of fitness and propriety, including tendering for providers to provide IT/systems.
- Carry out recruitment to manage processes.
- Educate certification regime functions on expectations and the process.
- Update manuals and procedures as well as training on induction and through period of employment. Consider mode of training.
- In relation to potential new hires, put in place processes to assess fitness and propriety including reference requests and criminal records checks.
- Update reference processes for former employees.
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