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Dear Clients and Friends,
Though the original proposals were easy to miss, as they were buried deep within FCA Policy Statement PS16/22, earlier in March the regulator progressed with implementing its proposals to change the requirements on regulated firms when providing regulatory references.
What has the FCA said?
Firms have long been required to provide a regulatory reference for a former employee when asked by another regulated firm and include all relevant information as reasonably determined by the firm. The FCA has now updated its application of those rules to coincide with changes brought about through implementation of the Senior Managers and Certification Regime:
In summary, firms now have an extended time-frame and some specified factors to consider when requested to provide a regulatory reference. Accordingly, clients are reminded to carefully consider the above, in consultation with their legal advisors, in the event they are asked to provide a regulatory reference. The provision and content of the reference provided can have legal and regulatory consequences.
If you wish to discuss this alert further, please contact Adil Khan or your regular ACA consultants.
ACA Compliance (Europe) Limited
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