statements of principle + code of practice for approved persons

what regime used to be in place to monitor authorised firms + approved ppl

APER - Approved Persons Regime

what regime is now in place to monitor authorised firms + approved ppl

SM&CR - Senior Managers & Certification Regime

when did this shift happen

from 2016-2019

BUT

SM&CR has existed since 2008 (in response to crisis, and LIBOR scandal)

who does APER apply to still

select roles, eg. Appointed Representatives under SUP 10A

two main controlled functions of APER

Significant Influence Functions (SIFs)

Customer Dealing Function (CF30)

who are SIFs for

directiors, CEOs, etc

who is CF30 for

client facing roles

who does SM&CR apply to

most FSMA authorised firms (but not the ones that use APER like appoined representatives)

3 main components of SM&CR

Senior Mangers Regime (SMR)

Certification Regime (CR)

Conduct Rules

who is SMR for

people performing SMFs (Senior Management Functions)

so like the directors, CEOs, CFOs, etc

what do you need to perform an SMF

• regulatory approval

• annual fitness/propriety assessments

4 key tools that are a part of the SMR

prescribed responsibilities —> allocated to SMFs with defined accountability

statement of responsibilities —> clarifies individual roles

management responsibilities map —> documents governance + oversight

duty of responsibility —> requires reasonable steps to prevent, stop or remedy breaches

PICK UP HERE FROM CERTIFICATOIN REGIME