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ABOLITION OF APPROVED PERSONS REGISTER

Published by Gbaf News

Posted on November 11, 2014

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

CISI Applauds FCA Accountability Reforms

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.

New Annual Certificate in Professional Competence

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.

Concerns Over Abolition of Approved Persons Register

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?

Advocating for Whistleblowing and Key Functions

“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.”

Key Takeaways

  • CISI supports FCA’s proposals under CP14/13 to bolster individual accountability in banking.
  • CISI expresses concern over abolishing the Approved Persons Register without replacing it with a public alternative.
  • CISI will offer a Certificate in Professional Competence and masterclasses to support competence maintenance.
  • CISI urges the creation of a firm-based Key Function to promote ‘Speaking Up’ and whistleblowing culture.
  • CISI calls for collaboration between trade and professional bodies, regulators, and consumer representatives on implementation.

References

Frequently Asked Questions

What is the Approved Persons Register and why is its abolition controversial?
The Approved Persons Register listed individuals approved by the FCA in controlled functions, enabling public transparency. CISI argues its removal without replacement reduces accountability and consumer trust. ([cisi.org](https://www.cisi.org/cisiweb2/cisi-website/who-we-are/press-release/2016/04/07/an-abolition-too-far-lack-of-a-central-register-to-check-who-is-an-authorised-adviser-is-causing-consumers-concern?utm_source=openai))
What does CISI propose to ensure competence under the new regime?
CISI will offer an annual Certificate in Professional Competence and masterclasses for senior managers and non‑executive directors to support ongoing competence assessment. ([globalbankingandfinance.com](https://www.globalbankingandfinance.com/abolition-of-approved-persons-register/?utm_source=openai))
How does CISI recommend addressing whistleblowing under the new framework?
CISI urges that firms designate a Key Function to champion 'Speaking Up' and whistleblowing, aligning with PRA-prescribed functions, to foster responsible leadership. ([globalbankingandfinance.com](https://www.globalbankingandfinance.com/abolition-of-approved-persons-register/?utm_source=openai))
What governance approach does CISI advocate for implementing these changes?
They call for dialogue and working groups bringing regulators, trade and professional bodies, the Banking Standards Review Council, and consumer representatives together for pragmatic rule implementation. ([globalbankingandfinance.com](https://www.globalbankingandfinance.com/abolition-of-approved-persons-register/?utm_source=openai))
What is the overall tone of CISI’s response?
Supportive of enhanced accountability, yet cautious—CISI welcomes proposals but warns that without safeguards like a public register, reforms could harm transparency. ([globalbankingandfinance.com](https://www.globalbankingandfinance.com/abolition-of-approved-persons-register/?utm_source=openai))

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