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FCA - CP 15/5 - Senior Managers Regime - Approach to Senior Non-Executive Directors

Response to the consultation

ABCUL strongly supports the proposals set out in this consultation.  Our members were deeply concerned about the potential for this regime to hamper their ability to function effectively due to the burden of compliance as well as their ability to successfully attract and retain quality

volunteers to staff their boards.  However, in tandem with PRA proposals to raise the threshold for their simplified regime to £250 million in assets, these proposals in relation to non-executive directors (which most credit union directors are) substantially address our concerns. 

We are also very supportive of the added provision to not require any pre-approval or notification in relation to NEDs for credit unions.  This is entirely appropriate given that credit unions are not subject to the same level of regulation which pertains for those impacted directly by EU regulation.

We would like to thank the FCA for taking on board the feedback it received in respect of its initial consultation and responding accordingly.  Credit unions were in no way responsible for causing the events which made the Senior Managers Regime necessary, nor do they presently represent a sufficient risk of consumer detriment or financial instability relative to other firms.  Therefore it is very welcome that a much-more proportionate regime is now proposed for the credit union sector.

Consultation questions

Q2. [FCA] Do you agree with the guidance in Appendix 3 concerning the roles and responsibilities of NEDs within the FCA SMR?

We are broadly satisfied with the guidance set out in Appendix 3 of the consultation on the roles and responsibilities of NEDs. 

Q5 – 7

No response.  Not applicable to credit unions.

We would be very happy to provide any further information or to answer any questions which the FCA may have in relation to our response.

You can find the full response available to download on the right hand side