Impact of Covid-19 on the Senior Managers and Certification Regime

UK regulators issue statements

partners Helen Marshall and Ezra Zahabi, and counsel Joe Hewton, in the Financial Services Regulatory practice, Akin Gump, London
Originally published in the April | May 2020 issue

On 3 April 2020, the Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA) (together the “Regulators”) issued statements regarding changes to the Senior Managers and Certification Regime for both dual and solo-regulated firms with respect to Covid-19. In light of the widespread repercussions of Covid-19 on the UK markets, underpinning the Regulators’ statements is the overarching message that whilst the Regulators acknowledge that flexibility is required in these unprecedented times, firms must continue to keep their governance arrangements under review and ensure a clear, written record of any decisions made. Most notably, the FCA has announced that, with respect to solo-regulated firms, it will permit unapproved individuals to step in and ‘act up’ as Senior Managers for up to 36 weeks (the position with regard to dual-regulated firms remains unchanged). We highlight below the key expectations for dual and solo-regulated firms in light of the Regulators’ statements.

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