The 13th August 2015 was not just an unlucky number 13 but the date the Prudential Regulatory Authority (PRA) and the Financial Conduct Authority (FCA) chose to publish the long awaited rules on the Senior Insurers Manager Regime. From the 1st January 2016 the regime will enable the PRA and FCA to hold senior executives and controlled and key function holders like the Chief Risk Officer, the Chief Actuary , the Chief Financial Officer and the Chief Underwriting Officer in Insurers and Reinsurers to account for wrongdoing and misconduct.
The regime will hold these “managers” accountable for decisions, poor decisions and even for “the way in which a person behaves in their private life”. the regime will identify these “managers” by requesting that the firm provide a governance map that will identify the individuals upon which the regulator can focus.
Insurers have not suffered the reverse burden of proof that has been imposed in the mirror regime for Banks ( the Senior Managers Regime) . For Banks if individuals are found culpable they need to “prove” they have taken such steps to avoid the breach. However insurer managers will still be subject to clear individual accountability.
It will be interesting to see if anyone wants to be an insurer and reinsurer manager when the new regime commences or whether they will take to the hills!