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20th January 2016

Accountability Rule Reminders

Following lessons from the Financial Crisis and to increase individual accountability within the Banking Sector, the FCA and PRA are introducing a number of policy changes - namely the Senior Managers Regime, the Certification Regime and Conduct Rules.

The Final Rules on Individual Accountability were published by the regulators in July 2015.

Banks: Are you ready?

Implementation for the banking sector on 7th March 2016 draws ever nearer. Firms should now be in their final stages of preparation and be reminded that the deadline for submission of Grandfathering Notifications to the FCA is in just over two weeks’ time on 8th February 2016.

Extension to all Regulated Firms

Once implemented for the Banking Sector, the Senior Managers Regime and Certification regime are, in all likelihood, to be extended across all sectors for regulated firms following an announcement and Bill submitted to Parliament by HM Treasury last year.

Assuming the Bill is passed by Parliament, the Industry will then wait to see how the regulator implements this across the board, with initial timetabling thoughts expected for a 2018 roll out.

Timetable: Individual Accountability Implementation

Individual Accountability Looms: Banks - Are You Ready?

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Grandfathering notification submission deadline

08 February 2016

Senior Managers and Certification Regime start date for the banking sector

07 March 2016

FCA expected to publish Final rules on the inclusion of wholesale activities in the Certification Regime

Q1 2016

FCA expected to publish the Final rules on regulatory references

Q1 2016

Whistleblowing rules become effective

07 September 2016

Application of Conduct Rules to banking sector staff who are not within the Senior Managers or Certification Regime

07 March 2017

Extension of Senior Managers and Certification Regime to all authorised firms

2018 TBC