On the 31st of January 2023, the Bank of England released a Consultation Paper that set out the Prudential Regulation Authority’s (PRA) proposals to extend the length of employment history required in long form A (the form used to apply for regulator approval to the appointment of a senior manager under the SM&CR). This extension would see the current five-year period increased to ten years – bringing it in line with MiFID requirements.
The PRA also intends to remove certain SM&CR forms from the PRA Rulebook. This includes forms A (long form), A (shortened form), B, E, I, J, and the Statement of Responsibilities with Forms C and D remaining in the PRA Rulebook. Despite the changes, the PRA would continue to direct firms to apply using the online notification and applications system (ONA).
The PRA considers that this will align the Senior Managers Regime application forms with other regulatory transactions like the Variation of Permission. It is also consistent with the approach adopted by the Financial Conduct Authority.
Removing some SM&CR forms from the PRA Rulebook would also allow the PRA to bypass the statutory consultation process when making administrative or other non-material changes to these forms. The PRA believes that this would reduce administrative costs, both for the PRA and for regulated firms, and reduce the time required to make non-material changes.
What happens next?
- The PRA has invited responses to this consultation with the deadline falling on Tuesday 28th of February 2023.
- It has been proposed that the changes resulting from the Consultation Paper would come into force in May 2023.