The FCA and PRA have begun consultation on:

1. a new Senior Managers’ Regime (SMR) to replace the old Approved Persons Regime (APER), but covering a narrower range of individuals than APER;
2. a new Certification Regime (CR), whereby firms would have to self-certify certain employees as ‘fit and proper’, and would apply to a wider range of individuals than APER; and
3. new banking conduct rules for individuals, based on the rules in APER, but applying to almost all a firm’s employees;

all of which will apply only to banks, building societies and PRA-authorised investment firms. APER will be abolished in this sector, but will continue to be in place elsewhere.

Responses to the consultation are required by Friday 31 October 2014.

The proposed regime change is extremely complicated: the result, perhaps, of combining two different systems (for PRA and FCA) into a scheme of late Byzantine intricacy.

Please click on the links below to read a report analysing the proposals.

Click here for more detail: http://bit.ly/1B8XPvG