Preparing for CBoI Senior Executive Accountability Regime

Course Outline and Objectives

While the IAR/SEAR legislation is still progressing and implementation is imminent, it is clear that the Central Bank of Ireland (CBI) proposals are very closely aligned with the Senior Managers and Certification Regime of the UK's Financial Conduct Authority which is now starting to deliver successful disciplinary cases against senior individuals.

Using the benefits of the UK experience to date, this course will focus on how the proposed requirements are likely to affect CBI regulated firms and their senior management teams, and give an idea of the roadmap and tasks that lie ahead, as well as useful preparation that can be undertaken now. The course will draw on the experiences of firms in the UK in project planning for and implementing this regulatory change.

By the end of the session, participants will:

• Recognise the reasons for global regulatory focus on individual and executive accountability
• Identify the proposed key features and elements of the Senior Executive Accountability Regime (SEAR), in particular how it will impact Board governance and Risk Management
• Recognise how the various aspects of the SEAR impact their individual job roles
• Develop an understanding of the potential application of Conduct Rules and the consequences for staff to whom they apply
• Recognise how the SEAR is likely to impact those staff who manage others
• How to deal with the April 2019 and November 2020 side letters
• Have a list of key tasks that will be required for implementation

Topics may include, but are not limited to:

• Duties and obligations
• Fitness and probity
• Outsourcing
• Demonstration compliance / Reasonable Steps
• Conduct Rules
• Breaches and disciplinary outcomes
• Regulatory referencing
• Action planning