The NACFB is 'actively encouraging' its members to respond and contribute to the Association’s overall response to an FCA Consultation Paper.
On 26th July 2017, the FCA published a proposal to extend the Senior Managers & Certification Regime to almost all regulated firms. NACFB, through its Compliance Services division, has created a survey which highlights the key questions likely to affect commercial finance brokers.
This new regime will essentially replace the Approved Persons Regime. The FCA proposes maintaining the exemption for firms who already have exemptions under the Approved Persons Regime. Such firms will be in a category called ‘Limited Scope Firms’, and will typically have fewer Senior Management Functions than firms in the core regime. This mirrors how the Approved Persons Regime currently applies to these firms.
The proposals do not affect Approved Persons of Appointed Representatives of firms. The FCA intends to confirm their approach to the SM&CR for Appointed Representatives in a follow-up Consultation Paper. Principal firms, including the Senior Managers of principal firms, remain responsible for ensuring that their Appointed Representatives and networks comply with their rules.
The NACFB said:
"NACFB members and other interested parties who have not yet had the chance to respond should do so and make sure their voices are heard."