The BBA and the Association for Financial Markets in Europe (AFME) have published their joint response to the FCA’s consultation paper CP 15/9 Strengthening accountability in banking: a new regulatory framework for individuals.

Key concerns raised in the response include:

  • That the proposed four week window in which cover may be provided for a certified person by an uncertified person is too short.
  • A request that rule breaches reported within the short timeframe allowed, if subsequently found to have been wrongly reported, be deleted from FCA records.
  • That more guidance should be provided on the different responsibilities of senior managers in executive and non-executive roles.
  • That the FCA should make a similar explicit statement as that given by the PRA, that they do not intend to apply standards “retrospectively” or with the benefit of hindsight.