Published on March 9, 2016
1. 1 Strengthening Accountability in Banking Senior Managers & Certification Regime Notes: These slides are based on those used for an event held on 20 July 2015 for professional advisers and have been updated with information on the regime for incoming branches of overseas banks. These slides summarise key information and should not be interpreted as Guidance. These slides have been updated to reflect the HMT announcement on 15/10/15 (stating their intention to remove the Presumption of Responsibility and the statutory requirement to report breaches of Conduct Rules) and the publication of PS15/30 for incoming branches on 16/12/15.
2. Contents • Overview of the new regime Slides 3-11 • Transitioning to the Senior Managers Regime Slides 12-31 • Certification Regime and Conduct Rules Slides 32-36 • Appendix Slides 37-44 2
3. Overview 3
4. Background (1/2) The Parliamentary Commission on Banking Standards (PCBS) recommended: • “A Senior Persons Regime... should provide far greater precision about individual responsibilities than the system that it replaces, and would serve as the foundation for… changes to enforcement powers…” • “A Licensing Regime… as the basis for upholding individuals' standards of behaviour, centred on the application of a revised set of Banking Standards Rules to a broader group…” The Banking Reform Act 2013 created the legislative framework. 4
5. Background (2/2) Through the new Accountability Regime: • Senior managers can be held accountable for misconduct that falls within their area of responsibility. • Individuals working at all levels can be held to appropriate standards of conduct. 5
6. Final rules for the Senior Managers & Certification Regime have been published. Still to come: • Extension of Certification regime to ensure a consistent approach to wholesale activity (under consultation). • Final Handbook consequential amendments. • Final rules on Regulatory References Accountability Our banking accountability regime in context 6 New Remuneration rules published in June 2015, bringing greater alignment between risk and reward. New rules to strengthen whistleblowing systems and controls in firms and to promote a culture where people can speak up were published in October 2015 and take effect in September 2016. Remuneration Whistleblowing
7. Significant Influence Functions Customer Dealing Functions All other staff Senior Management Functions Certification employees Other staff covered by Conduct Rules Ancillary staff (not in scope) Pre-approved by regulators and subject to Statements of Principle and Code of Practice Pre-approved by regulators and subject to fit and proper assessment by the firm Certified as Fit and Proper by the firm Subject to Conduct Rules Applies to Banks, PRA-designated Investment Firms, Building Societies, Credit Unions and Incoming Branches of Overseas Banks* The new accountability regime 7 *also known as Relevant Authorised Persons (RAPs)
8. • UK RAPs: Board (excluding ‘Notified NEDs’) and other individuals who hold key roles or have overall responsibility. NEDs captured are: Chairman of the Board, Chairs of Risk, Audit, Remuneration and Nomination Committees and Senior Independent Directors only. • Non-EEA Branches: Executive Directors of the branch and other individuals who hold key roles or have local responsibility. • EEA branches: Individuals with significant responsibility for significant business units of the branch and other individuals who hold key roles. Scope 8 Senior Managers Regime: overview (1/2)
9. • Pre-approval by regulators. • Annual assessment of fitness and propriety by the firm. • Regulatory power to approve applications with time limits or conditions. • Conduct Rules (including additional rules for Senior Managers). • Statements of Responsibilities. • Criminal records checks and regulatory references. • Criminal offence relating to a decision that causes a financial institution to fail. Features 9 Senior Managers Regime: overview (2/2) • Notified NEDs in UK RAPs (i.e. those that do not have a specified role on the board) will not be subject to the SMR, including pre-approval or the criminal offence etc. • The criminal offence also does not apply to credit unions or incoming branches. • Note: HMT is proposing to introduce a ‘duty of responsibility’ to replace the ‘Presumption of Responsibility’.
10. SMFs – PRA and FCA Certification employees - MRTs Other staff (covered by Conduct Rules) Ancillary Staff (not in scope) 10 Interaction between SM&CR and Remuneration Remuneration In scope of the Remuneration rules Out of scope of the Remuneration rules Other Certification employees (FCA only) Senior Managers Regime: • Senior managers holding a PRA SMF will be subject to the Remuneration rules • Senior managers holding an FCA- only SMF will only be subject to the Remuneration rules if they are an MRT Certification Regime: • Certification employees who are not MRTs will not be subject to the Remuneration rules. SMFs – FCA only
11. 11 Key messages for firms - now • A key purpose of the new regime is to improve genuine accountability in firms by removing ambiguity and clarifying individual responsibilities. We do not want to see a tick-box approach taken by firms, but genuine engagement. • Firms should be working now on how to apply the new regimes to their businesses. Firms must submit their grandfathering notifications and Statements of Responsibilities by 8 February 2016, before the new regime commences on 7 March 2016. • Firms are encouraged to submit via online forms, when these are available (forms for UK firms will be available earlier).
12. Transitioning to the Senior Managers Regime: what does this mean for firms? 12
13. Senior Managers Regime commences 7 March 2016 All grandfathering notifications to be submitted by 8/2/16 UK RAPs Feedback Statement / HMT confirmed extension of regime to foreign branches April May June July Aug. Sept. Oct. 2016 Nov. Dec Jan. Feb. March April May July Aug. Sept. Oct. Nov. 2017 Conduct rules apply to Senior Managers and Certified Persons. Certified Persons to be identified. Certified Persons to be issued with certificates by 7/3/17 Conduct rules apply to all other Financial Services staff Dec Certification transition Timeline 13 2015 MarchJan. Feb. Incoming Branches: *Near Final rules published 13/8/15 UK RAPs: Final rules effective 7/7/15 Jan. Feb. March April May June July Aug. Sept. Oct. Nov. Dec. June Incoming Branches: Final Rules effective 16/12/15
14. 14 Grandfathering: what does this mean for firms? (1/2) Firms should now be progressing preparations to: – identify relevant Approved Persons to grandfather to the new Senior Managers Regime – identify any new approvals required (i.e. for individuals not currently approved as Approved Persons but who will be performing a Senior Management Function at commencement) – prepare and submit a Statement of Responsibilities for each individual (per legal entity) who will become a Senior Manager
15. 15 Grandfathering: what does this mean for firms? (2/2) Firms should now be progressing preparations to: (cont’d) – construct and submit the Firm Responsibilities Map – submit documents with Grandfathering Notification Form (Form K) – identify individuals performing Significant Harm functions (specified by regulators) who will fall within the new Certification Regime. – train Senior Managers and Certified Persons on Conduct Rules before they take effect on 7 March 2016.
16. Mapping SIF holders to SMF functions for UK RAPs 16 CURRENT CF PRA SMF* FCA SMF Director (CF1) Partner function (CF4) Director of unincorporated association function (CF5) Chief Finance function (SMF2) Chief Risk function (SMF4) Head of Internal Audit function (SMF5) Head of Key Business Area (SMF6) Group Entity Senior Manager (SMF7) Credit Union Senior Manager (SMF8 – if CF1) Executive Director (SMF3) NED (CF2) Group Entity Senior Manager (SMF7) Credit Union Senior Manager (SMF8) Chairman (SMF9) Chair of Risk Committee (SMF10) Chair of Audit Committee (SMF11) Chair of Rem Committee (SMF12) Senior Independent Director (SMF14) Chair of Nomination Committee (SMF13) Chief Executive (CF3) Chief Executive (SMF1) Credit Union Senior Manager (SMF8) Compliance Oversight (CF10) Compliance Oversight (SMF16) CASS Operational Oversight (CF10a) Other Overall Responsibility (SMF18) Money Laundering Reporting (CF11) Money Laundering Reporting (SMF17) Systems and controls (CF28) Chief Finance function (SMF2) Chief Risk function (SMF4) Head of Internal Audit (SMF5) Significant management (CF29) Head of Key Business Area (SMF6) Group Entity Senior Manager (SMF7) Other Overall Responsibility (SMF18) *Approval of PRA-designated SMFs will be subject to consent from the FCA
17. 17 Mapping to SMF functions for incoming branches CURRENT CF PRA SMF* FCA SMF Non-EEA branches Director (CF1) Chief Finance function (SMF2) Chief Risk function (SMF4) Head of Internal Audit function (SMF5) Group Entity Senior Manager (SMF7) Head of Overseas Branch (SMF19) Executive Director (SMF3) NED (CF2) Group Entity Senior Manager (SMF7) None Chief Executive (CF3) Head of Overseas Branch (SMF19) None Systems and controls (CF28) Chief Finance function (SMF2) Chief Risk function (SMF4) Head of Internal Audit (SMF5) Other local responsibility function (SMF22) Significant management (CF29) Head of Overseas Branch (SMF19) Other local responsibility function (SMF22) Compliance Oversight (CF10) None Compliance Oversight (SMF16) CASS Operational Oversight (CF10a) None Other local responsibility function (SMF22) Money Laundering Reporting (CF11) None Money Laundering Reporting (SMF17) EEA Branches Significant management (CF29) None EEA Branch Senior Manager function (SMF21) Money Laundering Reporting (CF11) None Money Laundering Reporting (SMF17) *Approval of PRA-designated SMFs will be subject to consent from the FCA
18. 18 Allocating responsibilities during grandfathering – UK RAPs and non-EEA branches Allocating senior management responsibilities in practice: • Identify all entities in the group that are caught by the regime. • Consider what activities, business areas or functions are performed by each entity and which Prescribed Responsibilities will be relevant to them. • For each entity, identify those individuals that hold Senior Management Functions (1-17 for UK RAPs; and 2-22 for incoming branches, where applicable). • From this list, allocate the relevant Prescribed Responsibilities. • In addition, for each entity, identify any individuals that have overall or local responsibility for any other activities, functions or business areas. • Record the allocation of responsibilities on individual Statements of Responsibilities and a summary of these in the responsibilities maps.
19. 19 Statements of Responsibilities (SoRs) • SoRs should be submitted for each individual who is grandfathered. • New applications for SMFs in the run-up to commencement should also be accompanied by SoRs. • Electronic SoRs are now available to accompany applications.
20. How all this fits together Management and Governance arrangements Senior Management and their Statements of Responsibilities Reporting Lines *Allocation of Responsibilities How management and governance arrangements fit within the group Will need to include (amongst other things): 20 • We expect that smaller firms (i.e. those with gross total assets of £250 million or less), with less complex business models and governance arrangements will, in practice, have simpler responsibilities maps • Example Responsibilities Maps for small firms were provided alongside our final rules (in CP15/22) Management Responsibilities Maps *Does not apply to EEA branches
21. • EEA branches will be required to provide and maintain a responsibilities map. • However, some of the information required may overlap with information received as part of the ‘Programme of Operations’ (the ‘passporting information’) provided when an EEA branch passports into the UK. • Our rules seek to avoid duplication by only requiring EEA branches to provide: • Information which has changed since the passporting information was submitted, and has not been updated since; or • Additional information not included in the passporting information. • Where information is omitted, EEA branches should provide details in the responsibilities map of where this information can be found. • In practice, we will have regard to both the passporting information and the additional and updated information when considering the responsibilities map for EEA branches. • We expect that firms may find it easier and more effective to combine any previous and updated information into a single document. 21 Management Responsibilities Maps – EEA Branches
22. Territoriality • There is no ‘territorial limitation’ for the Senior Managers Regime. • Senior Managers are bound by the Conduct Rules regardless of whether or not they are located within the UK. • UK firms must allocate overall responsibility to a Senior Manager for all activities (including non-regulated activities), business areas and management functions of the whole firm, including those carried out from a branch overseas. • Non-EEA branches must allocate local responsibility to a Senior Manager for all activities (including non-regulated activities), business areas and management functions of the branch. 22
23. Swiss-based Senior Manager with overall responsibility for Corporate Investments within a UK Wholesale Bank New York- based Chair of Risk Committee of a UK Subsidiary of a US Retail Bank UK-based Senior Manager with overall responsibility for Retail Lending of a UK Building Society Conduct Rules Apply Territoriality – high-level, indicative examples for UK RAPs 23
24. New York- based Senior Manager with overall responsibility for Equities Trading within a UK branch of a US Bank UK based EEA Branch Senior Manager of a UK branch of a French Bank Conduct Rules Apply Territoriality – high-level, indicative examples for incoming branches 24
25. NB: Responsibilities should generally be performed by, or allocated to, one individual, but we accept that there will be limited circumstances where sharing or dividing a function or a responsibility may be appropriate. Types Roles Executive Roles • Traditional executive roles such as Chief Executive, Head of Overseas Branch and the Chief Finance Function* • Generic executive directors and individuals who head up significant business divisions Oversight (non- executive) Roles# • Core oversight roles discharged by non-executive directors, such as Chairman, Senior Independent Directors and the chairs of main board committees • Cannot be allocated overall responsibility for business activities or management functions • Can be allocated certain prescribed responsibilities Lines of defence and control roles • Key roles in the three-lines of defence model, such as Head of Internal Audit and Chief Risk Officer* • Technical roles such as Money Laundering Reporting Other* • Group Entity Senior Managers • Other Overall Responsibility or Other Local Responsibility Functions Broad Overview of Senior Management Functions *Not applicable for EEA branches #Not applicable for all incoming branches
26. Other SMFs: SMF 6 and 7 26 SMF Policy SMF 6 – Head of Key Business Area (PRA- designated) UK RAPs only Applies to a person who manages an area that has gross total assets of £10bn or more and which either: 1) Accounts for 20% or more of the gross revenue of the firm, or 2) Where the firm is part of a group, accounts for more than 20% of the total gross revenue of the group. SMF 7 – Group Entity Senior Manager (PRA- designated) UK RAPs and non- EEA branches • Applies to individuals who exercise significant influence over the RAP as part of their role in the wider Group. • They can be operating in either an executive or non-executive capacity.
27. Other SMFs: SMF 18 27 SMF Policy SMF 18 – Other Overall Responsibility Function (FCA) UK RAPs only • Applies to individuals who have overall responsibility for each of the activities, business areas and management functions of the firm (we have provided examples in our guidance). • Will apply only to those who also do not already hold another SMF. • They cannot be assigned Prescribed Responsibilities with the exception of ‘Overall responsibility for the firm’s compliance with CASS’. • SMF18s are not a direct replacement for the current CF29 (Significant Management function). This function is intended to allow flexibility for firms’ differing business models and governance. Allocation of Overall Responsibility: • We expect in many cases that overall responsibility will be allocated to individuals approved for one of the other FCA or PRA senior management functions. • If a firm’s complex legal structure is preventing it from allocating individual responsibilities clearly, this in itself suggests a regulatory risk which we would wish the firm to mitigate. • We recognise that our focus on individuals with ‘overall responsibility’ may, in practice, require firms to formalise existing arrangements between the Board and individuals who have been delegated responsibility for a function and are based outside the legal entity. We are not proposing to prescribe what this arrangement should look like.
28. Other SMFs: Non-EEA branches 28 SMF Policy SMF19 – Head of Overseas Branch • There is a requirement for all non-EEA branches to have at least one SMF19. • Will be responsible for conduct of all activities of the UK branch of an overseas firm subject to the UK regulatory system. • Should have the highest degree of individual decision-making authority within the branch. SMF22 - Other local responsibility function • This will operate in a similar way to the Other overall responsibility (SMF18) function for UK RAPs. • Captures any individuals that have local responsibility for any of the activities, business areas or management function of the branch, but who do not already perform any other SMFs in relation to the branch. SMF3 – Executive Director • This will operate in a similar way to the existing Director (CF1) function for non-EEA branches. • This function already exists in the SMR for UK RAPs, but for branches it will be limited to individuals performing a the function in relation to the activities of the branch, rather than in relation to the whole firm.
29. Other SMFs: Non-EEA branches 29 SMF Policy SMF16 – Compliance Oversight (FCA) • If a non-EEA branch is not currently required to have an individual approved to CF10, this will not change under SMR. • However, if a non-EEA branch is not required to have an individual approved to SMF16, they must still ensure that the prescribed responsibility on compliance is allocated to an appropriate senior manager of the branch. SMF2 – Chief Finance SMF4 – Chief Risk SMF5 – Head of Internal Audit • These only apply where a branch has dedicated individuals performing these functions. • However, the prescribed responsibilities framework for branches always requires a non-EEA branch to have an approved SMF who is responsible for risk management. If the branch does not have a CRO/SMF4, they must allocate this responsibility to another SMF, apart from SMF22. • The local responsibility requirements also require that, if a branch has finance/internal audit functions, they must also have an approved SMF with responsibility for these functions. These may be allocated to any SMF, including SMF22.
30. Other SMFs: EEA branches 30 SMF Policy SMF21 – EEA Branch Senior Manager • The EBSM function is based on the current Significant Management (CF29) function for EEA branches, which is limited to individuals that are involved in particular regulatory activities: • Accepting deposits • Designated investment business • Processing confirmations, payments, settlements, insurance claims, client money in relation to designated investment business • CASS (for EEA firms with a top up permission only) • The EBSM applies to individuals that have significant responsibility for a significant business unit that carry out any of these activities. • The EBSM is not limited to the most senior individuals – heads of sub- business units may also require approval as an EBSM if their business unit meets the ‘significance’ threshold. • Members of the governing body of the branch may require approval as an EBSM if they i) have significant responsibility for a significant business unit; and ii) do not perform a governing function in relation to the overall firm.
31. Submitting documentation • It is the firm’s responsibility to submit correct and clear documentation. • An online Statement of Responsibilities (SoR) template is available together with the Grandfathering Notification Form. • Firms are encouraged to submit via Connect where possible. • It will help the Regulators in processing these forms if firms submit their notification as soon as that are comfortable with it. Firms do not need to wait until the deadline. • Firms will only hear from the FCA if there is an immediate issue with their documentation. However, firms should not take silence from the regulator(s) as agreement that our requirements on notifications have been met. • For new SMF applications (for individuals who are not currently performing an equivalent controlled function or for vacancies), new forms will be made available with effect from 1 January 2016 in paper form. These must be accompanied by a Statement of Responsibilities for the applicant and the firm must complete a criminal records check for the applicant as part of the firm’s wider fit and proper assessment. 31
32. Certification Regime and Conduct Rules: what do they mean for firms? 32
33. Certification Regime: Overview • Material Risk Takers • Most former Approved Persons not covered by SMR* • Customer-facing roles with a required qualification • Proprietary traders • Line Managers of Certified People • Under consultation: extension to more wholesale market participants (such as traders) Scope • Annual Certification by firms • Certification Regime overseen by a Senior Manager • Regulatory references Features • The Certification Regime requires firms to assess the fitness and propriety of employees in roles which could pose a risk of significant harm to the firm or any of its customers. • It is the firm’s responsibility to make individual certification decisions; however, the regulators may challenge the overall effectiveness of a firm’s process. 33 *For EEA branches, the CASS significant harm function only applies to branches with a top up permission
34. • No ‘territorial limitation’ – The Certification Regime applies to them wherever they are based 34 Certification Regime: Territorial Limitation Material Risk Takers* All other Certified Persons • Are subject to the Certification Regime if they are based in the UK or dealing with a client in the UK only *In line with current consultation proposals for MRTs #For EEA branches, the Certification Regime applies in line with EU legislation For UK firms: For EEA# and non-EEA branches, the Certification Regime applies to individuals that are based in the UK only.
35. Conduct Rules 35 Rule Applied by First tier – Individual Conduct Rules (Certification Regime) CR1 You must act with integrity FCA and PRA CR2 You must act with due skill, care and diligence FCA and PRA CR3 You must be open and cooperative with the FCA, the PRA and other regulators. FCA and PRA CR4 You must pay due regard to the interests of customers and treat them fairly. FCA Only CR5 You must observe proper standards of market conduct. FCA Only Second tier – Senior Management Conduct Rules (Senior Managers Regime) SM1 You must take reasonable steps to ensure that the business of the firm for which you are responsible is controlled effectively FCA and PRA SM2 You must take reasonable steps to ensure that the business of the firm for which you are responsible complies with the relevant requirements and standards of the regulatory system FCA and PRA SM3 You must take reasonable steps to ensure that any delegation of your responsibilities is to an appropriate person and that you oversee this effectively FCA and PRA SM4 You must disclose appropriately any information of which the FCA or PRA would reasonably expect notice FCA and PRA
36. Conduct Rules: Territorial Limitation 36 Senior Managers & Material Risk Takers* Other Certified staff & Other Conduct Rules staff *In line with current consultation proposals for MRTs #For EEA branches, the Conduct Rules apply in line with EU legislation UK firms EEA# and non-EEA branches Senior Managers No territorial limitation – conduct rules apply wherever they are based Material Risk Takers* No territorial limitation – conduct rules apply wherever they are based Applies to individuals if they are based in the UK only Other Certified Persons Applies to individuals that are based in the UK or dealing with a client in the UK only Applies to individuals if they are based in the UK only Other conduct rules staff Applies to individuals that are based in the UK or dealing with a client in the UK only Applies to individuals if they are based in the UK only
37. Appendix • Implementation Roadmap • Future publications Roadmap • Useful information • Summary of Senior Management Functions • Prescribed Responsibilities – UK RAPs • Prescribed Responsibilities – non-EEA branches • Application of Certification Regime - Scope 37
38. 38 Date Theme Requirement 8/2/16 SMR • Submit Grandfathering Notification (incorporating Statements of Responsibilities and Firm Responsibilities Maps) 7/3/16 SMR • New Regime Commences • Conduct rules apply (Senior Managers must be trained beforehand) • Known and suspicious breaches become ‘reportable’ within 7 days of becoming known 7/3/16 Certification Regime • All Certified staff must be identified • Conduct rules apply (Certified staff must be trained beforehand) 7/3/17 Certification Regime • Certificates of fitness and propriety must be issued to all Certified staff • Fitness and propriety must be certified at least annually thereafter 7/3/17 Conduct Rules • Apply to all staff excluding ancillary staff (staff must be trained beforehand) Implementation roadmap
39. 39 Date Publication / Legislation Prior to 7/3/16 Final rules on the inclusion of wholesale activities in the Certification Regime Prior to 7/3/16 Final rules on regulatory references Note: On 15/10/15, HMT announced that it has introduced legislation to Parliament which proposes to extend the SM&CR to all FSMA-authorised firms by 2018, thereby replacing the existing Approved Persons Regime. Future publications roadmap
40. Useful information • Visit the FCA Website: – http://www.fca.org.uk/firms/being- regulated/improving-individual- accountability • All queries should be referred to the firms’ supervisors where appropriate or to the Contact Centre. 40
41. SMF PRA-designated functions* SMF FCA-designated functions SMF 1 Chief Executive SMF 3 Executive Director SMF 2 Chief Finance SMF 13 Chair of Nominations Committee SMF 4 Chief Risk SMF 16 Compliance Oversight SMF 5 Head of Internal Audit SMF 17 Money Laundering Reporting SMF 6 Head of Key Business Area SMF 18 Other Overall Responsibility SMF 7 Group Entity Senior Manager SMF19 Head of Overseas Branch SMF 8 Credit Union SMF SMF 21 EEA Branch Senior Manager SMF 9 Chairman SMF 22 Other Local Responsibility SMF 10 Chair of Risk Committee SMF 11 Chair of Audit Committee SMF 12 Chair of Remuneration Committee SMF 14 Senior Independent Director SMF 19 Head of Overseas Branch 41 Summary of Senior Management Functions *Applications for approval to PRA-designated functions will require consent from the FCA
42. Prescribed Responsibilities – UK RAPs 42 *Small firms are firms with gross total assets of £250 million or less Key PRA FCA Shared Ref Applicable to larger firms only FCA / PRA Allocate to a NED f Induction, training and professional development of all members of the firm’s governing body Shared Yes g Induction, training and professional development of all persons other than members of the governing body Shared h Overseeing the adoption of the firm’s culture PRA i Leading the development of the firm’s culture PRA j Internal Audit Shared Yes k Compliance Shared Yes l Risk control Shared Yes m Remuneration Code Shared Yes n Whistleblowing PRA Yes o Capital, funding and liquidity PRA p Treasury management PRA q Financial information and its regulatory reporting PRA r Recovery plan and resolution pack PRA s Internal stress-tests PRA t Firm’s business model PRA u Fitness & Propriety of notified NEDs PRA Ref Applicable to all firms FCA / PRA a Senior management regime Shared b Employee certification regime Shared c Responsibilities map Shared d Financial crime FCA e Allocation of all prescribed responsibilities PRA Ref Applicable to small firms only* PRA / FCA aa Risk management policies and procedures PRA bb Systems and controls PRA cc Firm’s financial resources. PRA dd Legal and regulatory obligations PRA Ref Applicable to specific types of firm PRA / FCA v Proprietary trading activities PRA w Risk management policies and procedures (if no Chief Risk function) PRA x Internal audit function (if outsourced) PRA y Ring-fencing requirements PRA z CASS FCA
43. Prescribed Responsibilities – Non-EEA Branches 43 Key PRA FCA Shared Ref Applicable to all firms FCA / PRA za Senior management regime Shared zb Employee certification regime Shared zc Responsibilities map Shared zd Risk Management Shared ze Compliance Shared zf Escalation of correspondence Shared zg Financial crime FCA zi Systems and Controls PRA zj Allocation of all prescribed responsibilities PRA zk Liquidity PRA zl Financial information and its regulatory reporting PRA Ref Applicable to specific types of firm PRA / FCA zm CASS FCA Note: Prescribed Responsibilities do not apply to EEA Branches
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