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Table for Grandfathering Provisions

For firms affected by the Senior Managers Regime, the regulators have put in place transitional arrangements for ‘Grandfathering’ those already approved under the existing Approved Persons Regime to the new Senior Managers Regime.

To help with the transition process, they have also published a Table of Grandfathering Provisions that map current controlled functions to the new designated significant management functions (SMFs) as summarised below.

Table of Functions:

Grandfathering to Senior Managers Regime (SMR)

Grandfathering from Approved Persons Regime to Senior Managers Regime

CURRENT CONTROLLED FUNCTION

NEW DESIGNATED SIGNIFICANT MANAGEMENT FUNCTION

All applicable firms (part from credit unions)

The following PRA controlled functions:

Director function (CF1)

Partner function (CF4)

Director of unincorporated association function (CF5)

4

PRA

Chief Finance function (SMF2)

Chief Risk function (SMF4)

Head of Internal Audit (SMF5)

Head of Key Business Area (SMF6)

Group Entity Senior Manager (SMF7)

4

FCA

Executive director function (SMF3)

The PRA's non-executive director controlled function (CF2)

4

PRA

Group Entity Senior Manager (SMF7)

Chairman (SMF9)

Chair of the Risk Committee (SMF10)

Chair of the Audit Committee (SMF11)

Chair of the Remuneration Committee (SMF12)

Senior independent director (SMF14)

4

FCA

Chair of the nominations committee function (SMF13)

The significant management function (CF29)

4

PRA

Head of Key Business Area (SMF6)

Group Entity Senior Manager (SMF7)

4

FCA

Other overall responsibility function (SMF18)

All applicable firms to which the function in the first column applies

Compliance oversight function (CF10)

4

FCA

Compliance oversight function (SMF16)

CASS operational oversight function (CF 10A)

4

FCA

Other overall responsibility function (SMF18)

Money laundering reporting function (CF11)

4

FCA

Money laundering reporting function (SMF17)

Credit unions

The PRA's director controlled function (CF1)

4

PRA

Credit Union Senior Manager (SMF8)

4

FCA

Executive director function (SMF3)

The PRA's non-executive director controlled function (CF2)

4

PRA

Credit Union Senior Manager (SMF8)

4

FCA

Chair of the nominations committee function (SMF13)

Summarised from the Transitional Provisions detailed in SUP TP 6.2.7

N.B. This does not apply to those who have been approved for functions under the Appointed Representatives provisions.
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Senior Managers Regime:

 Grandfathering Assistance & Support

We can provide support  and assistance in preparing for the Senior Managers Regime, including mapping out and allocating responsibilities, preparing Grandfathering Notifications and Statement of Responsibilities.