The PRA and FCA, have launched a consultation which could lead to major changes to the approved persons regime. The proposals are a result of high profile failures in the banking sector but the proposed changes will not only impact Banks but also Credit Unions. The proposals include:
- a Senior Persons Regime to replace the Significant Influence Function element of the Approved Persons Regime.
- Certification Regime applying to certain other Credit Union staff, and
- Conduct rules which would apply to a wider range of employees subject to regulatory approval.
 A cost benefit analysis has been carried out into the impact on each sector. The total one-off costs for the Credit Union sector, of the FCA proposals, is estimated to be in the region of 4.77m (equivalent to 2.9% of the sector’s income). In addition, there is expected to be ongoing costs of £1.24m (0.7% of sector income).
Responses to the consultation must be received by 31 October. This is a major change for Credit Unions and it is therefore important that all Credit Unions consider the impact of these proposals and contribute to the consultation. The consultation document and the cost benefit impact are both available on the PRA website.