Last year we discussed the regulators proposals to change the Approved Persons Regime. If approved the new proposals are due to come into force in spring 2016. The proposals are not straight forward mainly due to the differences between the PRA and FCA approaches, the volume of consultations and because there are still a number of unanswered questions. As a result, we have received a large number of queries from clients on the proposed Credit Union Approved Persons Regime changes. We have therefore decided to publish a series of blogs on this topic.
The proposed new Credit Union Approved Persons Regime consists of three tiers:
- Senior Managers Regime
- Certification Regime and
- Conduct Rules
The new system is designed to make someone clearly accountable for each aspect of the Credit Union’s operations. It will place greater responsibilities and scrutiny on individuals as it will now be clear to the regulator who to blame. It will therefore be vital that Credit Unions have an effective supervisory/internal audit function in place to ensure that systems are operating as they should be. The new system also raises a number of HR issues as well that Credit Unions will have to deal with.
The next article, on Credit Union Approved Persons Regime changes, will cover the proposed Senior Managers Regime. This article will, however, only be available to clients of the firm. We will also be covering this topic at our forthcoming Credit Unions of Glasgow training session.