Senior Individual Accountability in the UK Financial Services Environment: A Practical Handbook for Significant Influence Function (SIF) Holders

At a time when expectations of boards and senior management have never been higher; and with a Regulator committed to bringing more senior level individuals to account, Significant Influence Function (SIF) holders are increasingly concerned to understand the nature and extent of their regulatory responsibilities. However, this is not as simple as merely digesting the relevant high-level principles (and associated evidential provisions) contained within the rulebook – which will often bear little discernible resemblance to operational reality; and to those situations routinely encountered by SIF holders in practice.

This handbook aims to bridge this perceived ‘rule to reality’ gap; and answer, from a decidedly practical perspective, some of the key questions pre-occupying SIF holders (and prospective SIF holders) in today’s increasingly challenging regulatory environment:

• What do I need to know? What does the Regulator expect of me?
• What are the bounds of my responsibility?
• To what extent can I be held responsible for the (mis)conduct of others?
• How should I be conducting myself as a SIF holder? How far do I need to go?
• How should I approach regulatory interviews?
• Where am I most potentially vulnerable, in practice? What are the Regulator’s most likely avenues of challenge? How can I best protect myself?
• How do I reconcile my statutory duties as a director with my regulatory responsibilities?
• What assurances should I receive before signing an attestation? How should it be framed? What are the repercussions of getting it wrong?

Prudent SIF holders will strive to do all they can to avoid any form of regulatory criticism or sanction. It is hoped that this publication serves as a helpful practical starting point in achieving that objective.