Improving individual accountability: forms

Find out more about the new forms for banking sector firms that are subject to the Senior Managers Regime (SMR).

If you are an insurance firm subject to the Senior Insurance Managers Regime, please see our Individual accountability in the insurance sector page.

Senior Managers Regime

As part of the implementation of the new SMR, a new set of forms for individuals in relevant firms will be introduced.

The forms and accompanying guidance notes for the new regime are set out in the Table of Forms below. Links to the new forms are also contained in the new rules:

• CP15/22: Strengthening accountability in banking: Final rules
• PS15/30: Strengthening accountability in banking: UK branches of foreign banks (final rules)

Firms should refer to the rules to determine which forms they should submit to the FCA.

Grandfathering to the SMR: what you need to do now

Please submit your grandfathering notification no later than 8 February 2016.

Firms have until 8 February 2016 to submit a Grandfathering Notification Form K and Statement of Responsibilities at Grandfathering covering each currently approved person and person whose approval is pending at the date of submission. Revisions to a grandfathering notification Form K and Statement of Responsibilities (SoR) can be submitted before 7 March 2016. The electronic Grandfathering Notification – Form K and SoR are now available on Connect.

The remainder of the new forms will be available on Connect from 7 March 2016.

We advise you to access Connect via a Chrome internet browser, to ensure that you can access all functionality on the forms.

Please see the Senior Managers & Certification Regime Information Pack for more information.

Firms can also access a How to guide to find out how to complete the Electronic Grandfathering Notification Form via Connect (this includes the Statement of Responsibilities).

Credit Unions can also refer to the workshop for credit unions slides.

Who should complete the grandfathering form?

All firms within the scope of the SMR:

• banks (this includes incoming EEA and third country foreign branches)
• building societies
• credit unions
• the relevant PRA-regulated investment firms

All Relevant Authorised Persons (RAPs) firms, with the exception of Credit Unions, must use the Connect Form K.

New applications for the SMR

Some of the new forms, such as Form A (for approval to perform a Senior Management Function) and Form E (for approval to transfer into a Senior Management Function), can be submitted in advance in paper form from 1 January 2016. Applications in advance of the new regime should be made following the provisions in SUP 15.7.4R to SUP 15.7.9G in the FCA Handbook and Notifications 7 in the PRA Rulebook, and will be treated as having been received on 7 March 2016.

Most of the SMR forms are based on the existing forms, but the FCA and the PRA are also introducing two new forms:

• Form I (Application to Vary Approval)
• Form J (Significant Change to Statement of Responsibilities)

Table of Forms – RAPs

Form	Title	Notes   Unless otherwise stated new forms can be submitted from 7 March 2016
Long Form A	UK Relevant Authorised Persons and Third Country Relevant Authorised Persons only Application to perform senior management functions	Firms can submit paper form A from 1 January 2016. Applications received in advance of the new regime will be considered but not formally approved before 7 March 2016.
Short Form A	UK Relevant Authorised Persons and Third Country Relevant Authorised Persons only Application to perform senior management functions
Long Form A	EEA Relevant Authorised Persons only   Application to perform senior management functions
Short Form A	EEA Relevant Authorised Persons only Application to perform senior management functions
A – Guidance notes	Application to perform controlled functions	Guidance notes will follow in due course.
B	Notice to withdraw an application to perform controlled functions (including senior management functions)	Firms can submit this paper form from 1 January 2016, but only to withdraw an advance application made for approval under the SMR.
C	Notice of ceasing to perform controlled functions (including senior management functions)
D	Notification: Changes to personal information/application details and conduct breaches/disciplinary action related to conduct	This form can be submitted from 1 January 2016, but only to notify changes to an advance application made for approval under the SMR.
E	Internal transfer of an approved person (for firms and individuals subject to the senior management regime)	Firms can submit from 1 January 2016. Applications received in advance of the new regime will be treated as received on 7 March 2016.
E – Guidance notes	Internal transfer of an approved person	Guidance notes will follow in due course.
I	Application for the Variation of a Conditional Approval for the performance of a Senior Management Function
J	Notification of Significant Changes in Responsibilities of a Senior Management Function Manager
K	Grandfathering Notification	Firms have until 8 February 2016 to submit a grandfathering notification form K and SoR – Grandfathering, covering each currently approved person and person whose approval is pending at the date of submission. Revisions to a grandfathering notification Form K and SoR can be submitted before 7 March 2016.
SOR – Grandfathering	Senior Management Regime: Statement of Responsibilities at grandfathering
SOR – Grandfathering	Senior Management Regime: Statement of Responsibilities at grandfathering (EEA Relevant Authorised Persons only)
SOR – Grandfathering	Senior Management Regime: Statement of Responsibilities at grandfathering (Third Country Relevant Authorisde Persons only)
K – Guidance notes	Form K guidance notes
SOR	Senior Management Regime: Statement of Responsibilities	Can be submitted in advance from 1 January 2016, accompanying an advance application on paper Form A and Form E, depending on the circumstances.
SOR – EEA RAPs	Senior Management Regime: Statement of Responsibilities (EEA Relevant Authorised Persons only)
SOR – Non-EEA RAPs	Senior Management Regime: Statement of Responsibilities (Third Country Relevant Authorised Persons only)
SOR – Guidance notes	​Statement of Responsibilities	Guidance notes will follow in due course.

Information from the PRA

For information about the PRA’s approach to implementing the new regimes, and supporting material, please visit the PRA’s pages on strengthening accountability.