On 22 January 2021, the PRA published a policy statement (PS21/1) on updates to SM&CR forms. Subsequent to a July 2020 consultation paper on the proposed updates, the PRA received zero response; the updates are consequently entirely in line with the proposal. The appendices to the policy statement contain the updates to the following forms:
- The Notification Form. This form has been revised to:
- reflect the new FCA address and the new FCA logo
- update references to the PRA Rulebook and remedy an incorrect reference to the PRA as a limited company
- update references to the PRA Rulebook and the General Data Protection Regulation (GDPR) notification
- SM&CR Form L.- : Notifications of breach of conduct rules and related disciplinary action in relation to a person performing a certification function or a Conduct Rules non-executive director. Question 3.05 is reinstated, requesting notifying firms to detail any disciplinary action taken
- CRR Firms, Non-CRR Firms, Solvency II Firms, Non-Solvency II Firms: Forms Amendment Instrument 2021 (PRA2021/1). While this instrument makes consequential amendments to the Notifications Part of the PRA Rulebook, the update merely inserts a hyphen before the statement’s hyperlink to the instrument
The final rules and the updated versions of the forms apply from 22 January 2021.
Given the less than earth-shaking nature of these updates, the total lack of response to the consultation is perhaps not surprising. However, with all things regulatory and SM&CR in particular- complete mastery of the detail avoids an appointment with the lurking devil.