The BSA is pleased to respond to FCA CP17/25.  Our key comments are as follows; the BSA - 

• supports the extension of a senior managers and certification regime to the other regulated financial services sectors; and emphasises the importance of fairness, consistency and proportionality across all regulated sectors.
• raises some technical and practical concerns about certain subsidiaries of deposit-takers
• asks the FCA to be clear about any changes arising from the CP that also affect sectors outside of FCA solo-regulated firms (eg deposit-takers), so that there is no confusion between sectors about which rules do, and do not, apply, and
• calls on the regulators speedily to draw a line under any further changes to the SM&CR for deposit-takers, so that firms can get on with business as usual and regulators can properly assess the success or otherwise of the overall regime's implementation.

Read the full response