AFB Virtual Seminar: Senior Managers and Certification Regime: Examining the PRA and FCA’s Proposed Phase 2 Reforms and What Happens Next

The Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA) have recently published their Senior Managers and Certification Regime (SM&CR) Review: Phase 2 consultation papers (CP26/37 and CP14/26).

The consultations propose a significant package of changes intended to streamline the regime and reduce the regulatory burden.

Among the proposals are changes to Senior Management Functions, a streamlined approvals process, reforms to the Group Entity Senior Manager (SMF7) role, extending the 12-week rule, raising the reporting threshold for Conduct Rule breaches, simplifying Conduct Rule requirements and the proposed removal of the Certification Regime.

In this virtual seminar, BCLP will review the FCA and PRA proposals and explore their practical impact on AFB members. The session will consider how the proposals fit within the wider SM&CR reform programme and the key areas of proposed change. They will also cover the extent to which the feedback previously provided to the regulators has been reflected in the current Phase 2 proposals, and suggest potential areas where additional representations to the regulators may be helpful to protect the interests of AFB members.

Who should attend?

All those with an interest in governance, accountability and conduct frameworks within regulated firms, including senior managers, compliance professionals, legal teams, HR professionals and those responsible for SM&CR implementation and oversight.

Speakers

Polly James, Partner

Polly is an experienced financial services regulatory lawyer who helps financial institutions and their boards to manage regulatory risks arising in a broad range of situations spanning enforcement proceedings, supervisory interventions (e.g. s166 reviews and use of ‘own initiative powers’), whistleblower reports, FOS complaints and navigating legal/regulatory changes. In addition, Polly has significant experience in successfully preparing members of firms’ senior management for their regulatory approval interviews with the PRA and FCA. Having been on secondment to the FSA Enforcement Division, she knows what it feels like on both sides of the table.

John Budd, Counsel

John is a financial services regulatory lawyer based in London. He is a specialist in non-contentious advisory work with a particular focus on banking, payments and fintech. John advises clients on the full life-cycle of regulated businesses, including licensing matters, compliance with conduct of business and prudential rules, M&A and insolvency/wind-down. Before returning to private practice, John worked at the Bank of England. He draws on this experience at a regulator to find efficient and practical solutions for clients. John is listed as a “Rising Star” for Financial Services Regulatory/Non-contentious in IFLR1000.

Katherine Pope, Partner

Katherine advises businesses on the full spectrum of employment law and HR matters. Her practice includes handling disciplinary and grievance disputes, whistleblowing concerns, performance management, workplace reorganisations, and supporting businesses in managing employees with ill health. She has a particular focus on the financial services sector, and her work often involves a regulatory angle. She has worked extensively alongside the firm’s regulatory team on SMCR-related developments and matters.

Logistics

Fee:        Included in AFB membership

Format:  Online via Zoom

Date:      Wednesday 18 November 2026

Time:      12:30 – 13:45

There will be opportunity for questions throughout the session; however, if you would like to submit a question before or have any areas that you would like the session to address, please send them to the AFB at secretariat@foreignbanks.org.uk.

You will receive final event details a week before the event.