Industry response

FCA CP17/25: Extending the senior managers & certification regime to all FCA firms

Response by the Building Societies Association

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


Elaine Morton

Head of Legal, Conduct Risk & Compliance