Global Trustee and Fiduciary Services News and Views Issue 50

Prime, Futures and Securities Services | XXXXXX 34 EXTENDING THE SENIOR MANAGERS AND CERTIFICATION REGIME TO ALL FCA FIRMS Individual Conduct Rules The most senior people in firms. Anyone who performs a Senior Management Function needs to be approved by the Financial Conduct Authority. SENIOR MANAGER CONDUCT RULES ENHANCED FIRM REQUIREMENTS Extra requirements that only enhanced firms need to meet. Senior Management Functions Additional Senior Management Functions Duty of Responsibility Additional Prescribed Responsibilities Statement of Responsibilities Responsibilities Maps Criminal Records Checks Handover Procedures Prescribed Responsibilities * Overall Responsibility SENIOR MANAGERS REGIME CORE FIRM REQUIREMENTS + + People who aren’t Senior Managers but whose job can cause significant harm to the firm or its customers. All staff who perform financial services roles. This does not include ancillary staff. Examples include: NOT approved by the Financial Conduct Authority Firms to check suitability at the point of recruitment and at least annually thereafter CERTIFICATION REGIME OTHER STAFF Territorial limitation is applicable under the Certification Regime but will not apply under the Senior Managers Regime Security staff Cleaning staff Caterers Receptionists Fit and Proper Requirements (including Regulatory References) *Limited Scope Firms don’t need to do this