1. Initial scope: whom will it impact?
- Credit institutions (excluding credit unions);
- Insurance undertakings (excluding reinsurance undertakings, captive (re)insurance undertakings and Insurance Special Purpose Vehicles);
- Investment firms which underwrite on a firm commitment basis or dealing on own account or are authorised to hold client monies or assets or both; and
- Third-country branches of the above.
2. Senior Executive Functions (SEFs): who in the entity?
Board members, executives reporting directly to the Board and heads of critical business areas. These should broadly correspond to PCF roles under the current Fitness and Probity Regime.
Certain SEFs may be mandatory: firms will have the flexibility to structure their senior management team as they consider appropriate provided that all prescribed responsibilities, as set out by the Central Bank, are assigned to SEFs.
3. Mandatory responsibilities: what will be required?
The CBI will prescribe mandatory responsibilities for firms, which must be allocated to individuals carrying out SEFs.
This will ensure that there is an SEF accountable for all key conduct and prudential risks.
There is a general list of prescribed responsibilities applicable to all firms, with tailored lists for industry sectors and based on firms' scale and complexity.
4. Comprehensive Statements of Responsibilities: increased accountability
Each SEF will be required to have a documented Statement of Responsibilities which sets out their role and areas of responsibility.
Statements of Responsibilities will be required to be kept up to date and submitted to the Central Bank.
5. Responsibility Maps: a single source of reference
Responsibility Maps document key management and governance arrangements in a comprehensive, accessible and transparent single source of reference.
Responsibility Maps will be required to be kept up to date and submitted to the Central Bank.