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Financial services

Impact of the Certification Regime All functions identified as performing a certification function will cease to be an approved person by the regulator on the 7th March 2016. There will then be a transition year and by 7th March 2017, all relevant authorised persons need to have issued a certificate confirming that they have judged their certification functions as fit and proper to perform their role. This year of transition will pass all too quickly and those that perform certification functions and will become certified persons, need to be aware of the changes that affect them: setting out expectations on their role up to and after certification.

Of particular use will be information on how the shift from a one-off assessment of fitness and propriety by the regulator to an ongoing assessment by the firm will lead to a more rigorous process of documenting, recording and reporting competence. We should also not forget the additional responsibility this new regime will place on the managers of certified persons, who may not previously have been captured by the approved person regime.

Regulatory references The purpose of the proposed rules regarding regulatory references is to create as complete a picture as possible of an individual’s conduct record for new employers - seen by the regulators as an important tool in the drive to raise standards and ensure that individuals take responsibility for their own conduct. The aim is to stop ‘bad apples’ from moving from one organisation to the next without detection.

References need to be true, accurate, fair and based on documented fact. References will need to be produced by HR in conjunction with the line manager and Compliance. When hiring, references must be obtained and assessed before a certificate is awarded.


Assess fit and

proper to conduct their role?


Conduct Rules There is also an important message to deliver around the Conduct Rules. The Conduct Rules are a revised set of rules developed from the Statements of Principle for Approved Persons. They are a further attempt by the regulators to focus the conduct of individuals and make sure that their actions are appropriate to the situation in which they operate.

These Conduct Rules take effect on the 7th March 2016 for both senior managers and certification functions. As mentioned previously, the firm has a transition year in which to assess and certify their employees. However, anyone identified as a certified person will be immediately bound by the Conduct Rules; the new Conduct Rules apply whether the certificate has been awarded or not.

There is an important obligation on the relevant authorised persons to communicate the expectations for certification functions to understand and follow the Conduct Rules. With the wider application of these rules to most other employees from 7th March 2017, the need for appropriate messaging that can be communicated to a large audience in a role-relevant manner is clear.

Implementation Making Certification functions fully aware of the new accountability regime and enabling them to understand the impact this will have on their role is an important factor in the smooth implementation of any new policies and processes. Furthermore, ensuring that effective Conduct Rule training is provided before they come into force is essential.

Creating learning that sends a clear message to certified persons in advance of those changes taking place, will go a long way towards the regime’s successful implementation. As in all things, setting out the right expectations from the start makes the rest so much easier.

The purpose of the

proposed rules regarding regulatory references is to

create as complete a picture as possible of an individual’s conduct record for new employers | Graduate Recruiter 21

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