With implementation dates for regulatory reforms in the financial services sector fast approaching, most regulated businesses face a period of significant and sustained change in how they deal with employees. This includes the new certification and senior managers regimes, new whistleblowing and regulatory reference requirements, an expansion of the conduct rules and mandatory reporting of breaches.
Key dates for your diaries
- 8 February 2016: deadline for submitting grandfathering notifications in respect of approved persons; statements of responsibility and responsibility/governance maps under Senior Managers/Senior Insurance Managers Regimes to be submitted
- 7 March 2016: deadline for whistleblowers' champion to be appointed; revised conduct rules apply to Senior Managers/Senior Insurance Managers; certification process commences for the banking sector
- 7 September 2016: deadline for submission of Scope of Responsibility forms for all grandfathered senior insurance managers under the Senior Insurance Managers Regime; firms must comply with new whistleblowing rules
- 31 October 2016: annual submission to regulators of notifications of breach of conduct rules
- 7 March 2017: certification process in the banking sector to be completed and conduct rules apply to nearly all other employees
As acknowledged leaders in providing legal advice to insurers and other financial services businesses, we are well placed to assist you in understanding what will be required of your business, from reviewing your current processes, to designing, developing and implementing the changes necessary to comply with the new regimes and, as importantly, how to deal with issues stemming from them as they arise.
To handhold you through this process in the run up to the first implementation date and to ensure that you are Reg Ready in 2016 and beyond, over the next five weeks we will be publishing weekly email updates to guide HR, legal and compliance through the steps needed to implement the regulatory changes. Our first update will be a checklist showing key HR and compliance action points prior to implementation. After that, our updates will cover the regulatory implications of the following:
- Recruitment issues and training
- HR Policies and contracts, including amending disciplinary and performance procedures as well as coordinating with compliance teams about fitness and propriety assessments
- Handling demands from senior managers - indemnities, insurance, remuneration
- On and after exits and change of role: settlement agreements, handover and regulatory references