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By Kali Bagary | 15 DECEMBER 2016 |

The end of the year is a busy time for many. For others it gives us time to reflect and open up opportunities for change in preparation of a new year. As such, I recently returned to the PRA website to reflect on the Senior Managers Regime (SMR) and the Senior Insurance Managers Regime (SIMR) – with corresponding rules and regulations for both.

The deadline is March 2017, so I believe now is the time to remind you of what is required as there is still time to get everything in order. Whilst there are many similarities between the two, there are some specifics you should know about. I have taken some excerpts below for each, directly off the PRA website as a reminder. Under each section there is a further link to the PRA Websites, enabling you to read more and download pdfs.

SMR (from their website)

Submitting an application:

All firms must submit all applications via the Connect application system (in execptional circumstances an exemption from the FCA Customer Contact Centre may be granted).

Disclosure of information

Firms are required to disclose all matters relating to a candidate’s fitness and propriety. If a firm is not sure whether something may have an impact on a candidate’s fitness and propriety, the information should be disclosed. The PRA takes non-disclosure very seriously and may consider it to be evidence of current dishonesty. If in doubt, disclose.

Assessing and determining an application

Under section 61 of the Financial Services and Markets Act 2000 (FSMA), the PRA may approve an individual only where it is satisfied that a candidate is fit and proper to perform the Senior Management Function(s) applied for. When considering a candidate’s fitness and propriety, the PRA takes into account and be satisfied of the candidate’s:

  • honestly, integrity and reputation, ie that they will be open and honest in their dealings and able to comply with the requirements imposed on them;
  • competence and capability, ie that they have the necessary skills to carry on the function they are to perform; and
  • financial soundness.

    Non-responders

    During the course of their assessment, case officers may request further information from firms via email to help reach a decision. If the firm does not respond to this request within four weeks they are considered a ‘non-responder’. The PRA will make further reasonable effort to obtain the required information, but may reject a non-responder’s application at its discretion if the information is not forthcoming.

    Compliance

    All SMFs must comply with and meet the fit and proper test for approved Senior Managers as set out in section 61 of FSMA on an ongoing basis. The FIT section of the Rulebook provides further guidance on what the PRA will take into account when assessing individuals against this. Approved persons must inform their firm and the PRA of any matter that may impact their ongoing fitness and propriety.

    More SMR information and downloadable pdfs are here: Bank Of England/SMR

    SIMR – Senior Insurance Managers Regime:

    Submitting an application

    All firms must submit all applications via the Connect application system (in execptional circumstances an exemption from the FCA Customer Contact Centre may be granted).

    Disclosure of information

    Firms are required to disclose all matters relating to a candidate’s fitness and propriety. If a firm is not sure whether something may have an impact on a candidate’s fitness and propriety, the information should be disclosed. The PRA takes non-disclosure very seriously and may consider it to be evidence of current dishonesty. If in doubt, disclose.

    Assessing and determining an application

    Under section 61 of the Financial Services and Markets Act 2000 (FSMA), the PRA may approve an individual only where it is satisfied that a candidate is fit and proper to perform the Senior Insurance Management Function(s) applied for. When considering a candidate’s fitness and propriety, the PRA takes into account and be satisfied of the candidate’s:

  • honestly, integrity and reputation, ie that they will be open and honest in their dealings and able to comply with the requirements imposed on them;
  • competence and capability, ie that they have the necessary skills to carry on the function they are to perform; and
  • financial soundness.

    Non-responders

    During the course of their assessment, case officers may request further information from firms via email to help reach a decision. If the firm does not respond to this request within four weeks they are considered a ‘non-responder’. The PRA will make further reasonable effort to obtain the required information, but may reject a non-responder’s application at its discretion if the information is not forthcoming.

    Compliance

    All SIMFs must comply with and meet the fit and proper test for approved Senior Insurance Managers as set out in section 61 of FSMA on an ongoing basis. The FIT section of the Rulebook provides further guidance on what the PRA will take into account when assessing individuals against this. Approved persons must inform their firm and the PRA of any matter that may impact their ongoing fitness and propriety.

    More SIMR information and downloadable pdfs are here: Bank Of England/SIMR

    As always we are here to help you manage any aspect of the above. Our Fintech solution, infoFINIUM has been specially created by IT experts and led in the design by industry experts, who have many years’ experience in regulatory reporting. We invite you to peruse our range of services at www.techfinium.com


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