January 25, 2019

FCA Senior Managers and Certification Regime – CP 19/4

White & Case LLP

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White & Case LLP General counsels at FCA regulated firms will no doubt be relieved to see that in its latest Consultative Paper published yesterday the FCA has rowed back from its previous suggestion that "Head of Legal" should be a senior manager role within SMCR. As the FCA notes, so much of the Head of Legal's work relates to legal advice, the laws of legal privilege prevent it from using its powers over senior managers.

Optimising the Senior Managers & Certification Regime and feedback to DP16/4 – Overall responsibility and the legal function

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.