In which format should I provide a Regulatory reference?

The FCA provides a template which all firms should use when providing a regulatory reference.[1]  This can be found in Annex 1 of SYSC 22 and details a baseline minimum of information which must be provided by firms.  Minor formatting changes to the FCA template are permissible, but all relevant information must be included.[2]

Firms are also free to provide more information if they wish (this is called “Additional Materials”).[3]  They may also add qualifying information if they want to (for example, information about mitigating circumstances).[4]

At a minimum, the FCA Regulatory Reference template requires the following information to be disclosed[5]:

  1. the name, contact details and firm reference number of the firm providing the reference (or names, contact details and firm reference numbers (where applicable) of group firms providing a joint reference);
  2. the individual’s name (i.e. the subject of the reference);
  3. the name, contact details and firm reference number of the firm requesting the reference;
  4. the date on which the reference was requested;
  5. the date of the reference itself;
  6. whether the individual has performed a certification function or been an approved person in the last six years;
  7. whether the individual was:
    1. a notified non-executive director;
    2. a credit union non-executive director;
    3. a key function holder (other than a controlled function);
    4. a non-SMF board director; or
    5. whether the individual performed any other role.
  8. whether the firm concluded that the individual was fit and proper to perform his/her role (and associated detail if the individual was held to be NOT fit and proper);
  9. disclosure of any other information that may be relevant to a fit and proper assessment.


[1] SYSC 22.4.1G

[2] SYSC 22.4.2R

[3] SYSC 22.4.6R

[4] PS16/22 “Strengthening accountability in banking and insurance: regulatory reference final rules”, page 11

[5] SYSC 22.2.2(4)

Everything you wanted to know about SM&CR - but were afraid to ask!

New to SMCR – or need a hand getting up to speed withj SMCR compliance? This guide will help you understand and implement every part of the SM&CR. You’ll learn, amongst other things:

  • How firms are classified.
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  • The Responsibilities of a Senior Manager.
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