Banking Standards Board Consultation on Certification process guidance
The Banking Standards Board (BSB) yesterday (13 July) published a Consultation paper setting out its proposed guidance for financial services firms within the Senior Managers and Certification Regime (SMCR). These firms are required to certify their Certification staff population annually as Fit and Proper (F&P), and given that firms have approached the first rounds of the certification process in a range of ways, there have been calls for some degree of unity and uniformity of approach. The consultation will therefore be of interest both to firms currently within SMCR but also those FSMA regulated firms which will be caught by the planned extension of SMCR in 2018.
The latest draft guidance from the BSB is designed to support the BSB’s Statement of Good Practice 1 on Fitness and Propriety Assessment Principles, and the supporting guidance which were published earlier this year in February. The new draft guidance has been drawn from various firms’ current experience of managing the certification process and is designed to help firms and individuals making certification decisions, particularly in cases where the decision is not clear-cut. The guidance sets out:
- Factors to consider when evaluating the evidence to be used in assessing F&P
- An overview of the options available to firms in making certification decisions
- Examples of dealing with certification risks and issues; and
- Good practice in recording the outcomes of an F&P assessment
The guidance also points out that maintaining F&P is the responsibility both of firms and of the Certified population themselves: firms need to allow Certified staff the appropriate time and resources to maintain their levels of competence and capability, and to address their own personal development.
The Consultation closes on 29 September 2017.
To discuss the consultation in more detail, or for advice on how to manage your firm’s obligations under the current or proposed SMCR regimes, please get in touch.