Significant influence functions

Find out how we assess applicants for key positions at a firm.

We regulate two types of individual:

  • those with significant influence over a firm’s conduct, and
  • those dealing with customers (or their property)

To ensure firms are effectively governed and able to deal with their customers fairly, only individuals with the appropriate skills, capabilities and behaviours should be appointed to these positions.

Firms must have balanced and effective boards, with a competent executive team, so we consider any appointment in this light.

We assess applicants for key positions to make sure they are up to the job and that they carry out their role effectively. We will continue to take a risk-based approach to approving individuals who perform controlled functions.

For significant influence functions (SIF) in higher-impact firms, we will interview where appropriate. Applicants do not have to sit a formal exam, but we do expect them to be able to demonstrate experience, competence and knowledge in the function that they apply for.

PRA approvals

For dual-regulated firms, the PRA leads on looking at approval applications for PRA-designated SIFs, but they need our consent first. If we do not give this, the PRA has to refuse the application.

If we and the PRA request an interview, we will try to coordinate a single, joint interview - however both organisations can hold interviews on their own, as long as the other party is informed and satisfied.

Evidence we need to see

Your firm should demonstrate that it has a robust recruitment process in place and to carry out the appropriate level of due diligence on all its candidates. However, when applying for a SIF, you should provide supporting evidence such as:

  • CV
  • role specification
  • organisation chart
  • board/executive team biographies
  • recruitment, referencing, interview and appointment processes
  • skills gap analysis
  • skills mapping document
  • learning and development plan

The interview

We may interview candidates applying for SIF roles, depending on the risk involved. We weigh up our knowledge of the firm, candidate and the role’s significance in the firm.

Typically, we consider interviewing anyone applying for these SIF roles:

  • chairperson
  • senior independent director
  • chair of risk or audit committee
  • chief executive officer (group or UK)
  • risk director/chief risk officer
  • finance director/chief finance officer (solo-regulated firms)
  • compliance oversight
  • CASS oversight

But if we have concerns about an individual’s fitness and propriety or about their firm, we can choose to interview for a role at any level or at any firm.

We would expect people to understand and be able to fully explain their regulatory responsibilities, their role and how their knowledge or experience equips them to carry out these functions.

The interview also looks at awareness and understanding of:

  • the market which the firm operates in
  • the firm’s business strategy and model
  • risk management and control
  • financial analysis and controls (for solo-regulated firms)
  • governance, oversight and controls
  • our regulatory framework, requirements and expectations

The composition of the interview panel will be determined by the firm type and role, and will usually include representatives from authorisations and supervisions, as well as a senior adviser.

If we are satisfied with the person’s fitness and propriety, we will approve the application and confirm this in writing.

If their level of competence did not satisfy the panel, we would tell the firm and explain the next steps. These may be to refuse the application or invite the person to attend a second interview.