On 6 October 2015, the PRA and FCA issued a Consultation Paper (with responses due by 7 December 2015) in relation to employment references for candidates applying for certain roles, including senior management functions under the Senior Managers Regime and significant harm functions under the Certification Regime.

Under the proposals, firms would:

  • be required to enhance their systems and controls relating to the retention of records, and the policies and procedures for requesting and providing references; and
  • not be able to agree to limit their ability to disclose information relevant
    to employment references.

The purpose of the proposals, which are part of a wider effort to improve accountability within banks and insurers, is to tackle the risk posed to the financial system of individuals with poor conduct records moving from firm to firm without relevant information about them being disclosed to future employers.