Citi 2018 FinReg Outlook

Senior Manager and Certification Regime Introduced in 2016, the Senior Manager and Certification Regime (SMCR) applies to banks and insurers. The FCA is extending the SMCR to all regulated firms, including asset managers. SMCR makes senior managers and certain key staff personally accountable for their actions. The SMCR also requires senior management and key staff involved to be annually certified as fit and proper for their job. The extension of SMCR is expected to go live by the end of 2019. Fund Governance The FCA has proposed various measures to enhance the governance of UK funds, including introducing independence and increased responsibility on fund boards, and extending the application of the SMCR. These proposals would bring UK fund governance more in line with the standards of global fund hubs, such as the US, Ireland, and Luxembourg. Final proposals are expected in the first half of 2018. Breaking down the FCA’s key areas of focus for the foreseeable future. Last year, the UK Financial Conduct Authority (FCA) published its sweeping Asset Management Study, the culmination of a multi-year review of the UK industry. The publication of the report is really just the beginning of the regulatory journey. The results of the study will drive the FCA’s policy agenda for the foreseeable future, and has the potential to reshape asset management in the UK. In the coming year, the FCA’s focus will be on developing potential new regulations. This will result in consultations and policy debates on a number of key issues, some of which are already underway. It is vital the industry be engaged in this process, since this is when opportunities exist to influence the direction of any new rules before the die is cast. The key areas the industry should focus on are: Reshaping the UK Asset Management Landscape SEAN TUFFY Head of Market and Regulatory Intelligence, EMEA, Custody & Fund Services EMEA 23 22 Citi Custody & Fund Services – FinReg Outlook 2018

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