The PRA and FCA have confirmed their approach to non-executive directors (NEDs) under the Senior Insurance Managers Regime (SIMR).  Some NEDs will have to be pre-approved by the regulator; others, so-called “Standard” NEDs, will not.

In practice, the position of Standard NEDs in insurance companies may not be significantly different from that of pre-approved NEDs:

  • Insurers will need to satisfy themselves that all new NEDs are fit and proper according to Solvency II standards;
  • All NED appointments will be subject to PRA/FCA scrutiny, but Standard NEDs will only be looked at once they are in post; and
  • All NEDs must comply with conduct rules.

This latest consultation paper (PRA CP7/15; FCA CP15/5) builds on proposed reforms of the Approved Persons Regime for insurers and reinsurers that were published by the PRA and FCA in November last year.  It also covers NEDs caught by the Senior Managers Regime for banks.

Our discussion is limited to consideration of the impact of the NEDs proposals on the insurance sector.  The deadline for responses is 27 April 2015

Please click here to read our briefing on the NEDs proposals.

Please click here to read our briefing on last November’s consultation