Over the coming weeks, we will continue to delve into the detail of the Individual Accountability Framework (IAF), address some of the trickier aspects of the regime and provide practical guidance for regulated financial services providers as part of our IAF Series.
In this Part 2, we set out eight practical steps that firms who are in-scope of the Senior Executive Accountability Regime (SEAR) should action.
When working through these key steps, in-scope firms must continue to bear in mind that the purpose of SEAR is to improve governance, performance and accountability by placing obligations on in-scope firms and their senior individuals to clearly set out where responsibility and decision-making lie.
The first action is to identify the relevant pool of in-scope individuals from the workforce. All Pre-Approved Controlled Function (PCF) holders within in-scope firms are captured by the SEAR requirements.
The next step is to map out the current responsibilities for each PCF holder and categorise their current responsibilities as "inherent", "prescribed" or "other".
This step will require careful diligence by in-scope firms but is the necessary preparatory work and, indeed, the first draft of what will become the requisite Statement of Responsibility (SoR) for each PCF.
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