ABOLITION OF APPROVED PERSONS REGISTER

“…runs against grain of making banks transparent” says CISI

The Chartered Institute for Securities & Investment (CISI) welcomes proposals by the FCA to strengthen accountability in the banking sector, as detailed in the paper CP14/13: Strengthening Accountability in Banking: A new regulatory framework for individuals. The proposals require individuals in key positions in their firms to take greater personal responsibility and accountability for decisions which may impact their firm, and that those decisions will be in the public interest.

To introduce a clear metric which makes firms annually evaluate the competence of senior managers and certificated staff having a material impact on their firm, is a prudent and proportionate step in the light of the public reputation of the sector, says the CISI in its feedback to the proposals.

The CISI also announces that it will be offering an annual Certificate in Professional Competence, focusing on the maintenance of competence with pragmatic and flexible eLearning to support the sector, together with dedicated opportunities for Masterclasses for senior managers and non-Executive Directors.

Simon Culhane, Chartered FCSI and CISI CEO, said: “We do, however, have a real concern regarding the abolition of the Approved Persons Register without a further public register being put in its place for the many thousands of such staff working in banks. A public register is a key bulwark which customers, future employers of staff in banks and professional bodies that monitor the standing of their members all find merit in. It runs against the grain of making banks transparent. How otherwise will customers be able to check they are dealing with a competent adviser or manager?

“We also urge the FCA to make provision for a role within the firm, a Key Function, to champion the importance of ‘Speaking Up’ and whistleblowing; it is a Prescribed Function within the PRA proposals and we believe this would give added value to the drive for genuine responsibility amongst leaders and senior managers in firms for these.

“Above all, we urge dialogue to ensure that the detail of the new PRA and FCA Rules will be pragmatic and workable and strongly urge the establishment of working groups, bringing together Trade Bodies and Professional Bodies to work through the implementation plan with the regulators and other stakeholders such as the Banking Standards Review Council and consumer representatives.”