PRA – Consultation to Amend Senior Managers Regime Forms

The Prudential Regulation Authority has published a short consultation proposing amendments related to application forms required under the Senior Managers & Certification Regime (SM&CR). This briefing will address the two proposals being made in the consultation, which are:

1. a)To remove certain SM&CR forms from the PRA Rulebook
2. b)To extend the length of employment history required in the long form A

roposal to Remove SM&CR forms from the PRA Rulebook

The PRA proposes to amend the Senior Managers Regime – Applications and Notifications Part of the PRA Rulebook to remove the direct links to long form A, short form A and form E, as well as the statement of responsibilities. Credit unions would still be required to submit forms using the same process.

The purpose of removing the forms from the rulebook directly would be to allow the freedom to make administrative and non-material changes to SMR forms without a formal consultation of industry. The PRA states that its motivation for this change is to make future improvements to the usability of SMR forms with a process that is less time-consuming for both the PRA and firms. The PRA states that it would still consult industry for material amendments, and that firms would notify firms of non-material changes that have been made.

The PRA highlights that other regulatory forms are not within the PRA Rulebook, and that this approach to forms is also taken by the FCA. ABCUL does not object to this proposal provided credit union are given suitable notice of an amendments to the SMR forms.

Proposal to Extend the Length of Employment History Required for Long Form A

The second proposal the PRA makes in this consultation is to extend the length of employment history information available for Long Form A from 5 years to 10 years. Long Form A is required for credit unions when applying for SMF permission for an individual that has not held an approved persons role within the previous 6 months

The Employment History section would not require employment references going back 10 years, but would require information about the employer, the period of employment and the nature of the role. The PRA note that, since applicants must already provide a CV with the Long Form A application, the extension to 10 years of employment history would not cause inconvenience to firms or SMF applicants.

ABCUL would assess that this change would not put in place a barrier to individuals applying for a SMF role at a credit union. However, if you would view this change to provide an barrier to entry to for credit union staff/directors taking on the required SMF 8 and SMF 17 roles, please get in touch with this feedback.