Management and business planning (8) Flashcards
What are the 3 areas does a modern day lending banking need to consider?
1 - Management
2 - Non financial analysis
3 - Financial analysis
What components of a business’ management should a lending banker be considering?
- Who runs the business and how well they do it?
- Can they deliver their promises to the bank?
Why does the lending banker need to assess Management , non financial info and financial info?
- To determine the ability of the customer to repay borrowings
- Establish the future threats to repayment
- Establish an alternative source of repayment if lending on a secured basis
- Ensure all risks are identified
What is the objective of the Senior Managers and Certification Regime (SMCR)?
To regulate individual conduct and standards in banking.
As a result of LIBOR, market manipulation and the 08 crash
What is the approved persons regime (APR)?
A firm could not employ a person in a “controlled function” unless that person had been approved by the Prudential Authority (PRA) or the Financial Conduct Authority (FCA)
The Senior Manager Certification Regime SMCR has 4 main components to it, what are they?
1 - Senior Management Regime (SMR)
2- Certification Regime (CR)
3 - Rules of Conduct (RoC)
4 - Fitness and proprietary rules (FFR)
What is the Senior Managers Regime (SMR)?
Ensure senior members are professionally fit to perform their role and that before a new senior member is appointment they must be checked approved
Do individuals who fall under the SMR need to be approved by regulators?
Yes
Certificate Regime (CR)
The CR applies to staff who do not carry out a senior management function but who could pose a risk of significant risk to the firm or its customers (e.g. staff who give investment advice)
Who is typically affected by the Certificate Regime (CR)?
- Material risk takers
- Those in customer facing roles e.g. advisors
- Managers of certified positions
- ‘Significant influence’ function roles
Do those under the CR need to be approved by regulators?
No, it is instead the responsibility of senior management
What do the rules of conduct enforce and who do they apply to?
Under the SMCR, the regulators have the power to make rules of conduct that apply to senior managers, certified persons and other employees (so everyone?).
As the rule target a broad range of staff, this will instil standard of good conduct across the industry.
Who is affected by the individual conduct rules
All banking employees except (cleaners, catering, reception etc)
What are the fit and proprietary rules (FPR)?
All institutes must ensure that those individuals under the SMCR are verified as being ‘fit and proper’ to exercise their duties
What checks will be carried out to determine if an individual is fit an proper?
- Criminal record checks
- Financial credit checks
- Employment reference (last 5 years)
The FCA’s handbook to test if an individual is fit and proper will ensure employees act with?
- Integrity
- Skill, care and attention
- An open and cooperative manner
- Act in the interest of customers
They must also check a new starters previous 5 year working history, to ensure they have adhered to these rules
What 2 elements or breach are required for the regulator to take enforcement?
1 - The firm has broken the regulatory requirements and that the breach occurred in the area business area that a Senior manager is responsible for
2 - If senior manager cannot prove they took the steps a normal person would have to prevent the breach