How have regulated
firms performed under
the regime?

The Senior Managers’ Regime came into effect on 7th March 2016, for firms that accept deposits,
and dual regulated investment firms.

Anyone already covered under APER was grandfathered into Senior Management Functions and companies were required to provide a Statement of Responsibilities for each senior manager, along with a Management Responsibilities Map.

The FCA subsequently conducted its first supervisory review of these documents for all firms with an allocated supervisor and a sample of firms without.

This review was published on 28th September 2016 and considered to what extent the rules had been met.

Whilst it was apparent that many companies had invested considerable time and effort to comply, not everyone had succeeded.

In some cases, it wasn’t clear whether firms had identified sufficiently senior individuals to hold Senior Management Functions.

In others, not all business functions had been allocated as responsibilities or there wasn’t enough detail about their scope.

There was wide variation in the quality of responsibilities maps, some with unclear or missing information.

This included governance arrangements and was particularly noticeable where the firm was part of a larger group.

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