This podcast summarises the key themes and expectations
outlined by the Financial Conduct Authority (FCA) regarding Fitness & Propriety (F&P) assessments for Senior Management Functions (SMFs) and Certification Staff within regulated firms.
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Key Themes:
1. Stringent Assessment: The FCA mandates thorough and regular F&P assessments to ensure individuals in key roles are suitable and maintain this suitability throughout their tenure. These assessments go beyond a simple 'tick-box' exercise.
2. Core Assessment Criteria: The FCA's FIT (Fit and Proper test for Employees and Senior Personnel) handbook details the core criteria:
• Honesty, integrity, and reputation: A spotless track record and demonstrably ethical conduct are paramount.
• Competence and capability: Individuals must possess the requisite skills and knowledge for their specific roles, including managers.
• Financial soundness: Sound personal finances indicate responsible behaviour and reduce the risk of vulnerability to financial inducements.
3. Active Senior Management Oversight: The FCA expects active involvement of relevant SMFs in overseeing the F&P process. This includes ensuring robust reporting mechanisms and not simply delegating the responsibility.
4. Integration with Existing Processes: Firms should seamlessly integrate F&P assessments into their HR and performance management frameworks. This includes establishing clear procedures for managing individuals who fail to meet the F&P criteria.
5. Robust Training and Guidance: Managers require adequate training and clear guidance on the firm's F&P approach and their responsibilities within the process.
6. Proportionality for Smaller Firms: While smaller firms may need to adapt certain indicators, the overall effectiveness of their F&P assessments and adherence to the Certification Regime should not be compromised.
7. Transparency and Information Sharing: The FCA expects firms to conduct thorough due diligence, including obtaining and reviewing regulatory references that disclose any misconduct or relevant concerns. These references should be provided promptly and contain all necessary information.
"Firms should demonstrate that they are making regular,
thorough and consistent assessments of the F&P of SMFs and Certification
The FCA's F&P requirements underscore the importance of
ensuring individuals in key positions within regulated firms maintain the highest standards of honesty, integrity, competence, and financial soundness. This proactive approach seeks to mitigate risks, enhance market integrity, and bolster consumer confidence in the financial services industry.
