On 23 January 2019, the FCA published a Consultation Paper (CP19/4) concerning further amendments to the Senior Managers and Certification Regime (SMCR). For private banks which are already subject to the SMCR, the consultation sets out the following key proposals:
..Excluding the Head of Legal from the scope of the Senior Managers Regime (SMR)
..Excluding individuals performing purely administrative functions from the scope of the Client Dealing Function.
Please see full publication below for more information.