On Friday 3rd April, the FCA published further guidance for firms and Senior Managers in relation to issues arising from the COVID 19 pandemic. Within the update, the FCA provided clarification in relation to a number of areas. These include:
Allowing an extension of the 12-week rule for Senior Manager function holders, without requiring approval, for up to 36 weeks, subject to certain conditions being met;
Clarification that Statements of Responsibility do not need to be re-submitted to the Regulator where Senior Managers are fulfilling roles on a temporary basis as a result of the COVID 19 pandemic and;
Clarification that firms do not need to allocate their firm’s COVID 19 response to a single Senior Manager. Instead responsibilities should be allocated in the way which best enables the firm to manage the risks it faces.