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Preparation of Senior Staff for Regulatory Approval

Regulators in the U.K. and elsewhere expect firms to perform proper due diligence in assessing candidates for a Significant Influence Function (SIF) or equivalent role in the financial services industry.

Interviews conducted by regulators are rigorous. For example, the FSA has publicly stated that a meaningful percentage of candidates are found not to be competent in the U.K. An additional proportion of candidates are approved, albeit with restrictions. Preparation ahead of regulatory approval interviews is critical to ensure candidates are able to demonstrate competence and an awareness of their development needs.

Promontory has extensive experience and success in preparing board-level (up to and including chairman) and senior management candidates for FSA and equivalent Approved Person Interviews. Drawing on our experience as former members of FSA senior management, where many of us performed these interviews, we use our extensive knowledge of regulatory practice to provide constructive feedback to individuals, including guidance on identifying and addressing shortcomings.

Promontory can assist firms and individuals in a variety of ways in advance of approval interviews. In addition to conducting practice interviews, we prepare and/or comment on gap analyses and development plans and source and deliver specific briefings for candidates.

Representative Engagements

Several major UK financial institutions have retained Promontory to provide assistance for all members of their boards and executives who may be called for an FSA new hire or role change approval interview. The support includes: a review of FSA expectations of Approved Persons, a practice interview, feedback from the interview as to style and areas for further development, and the assessment or design of induction programs. These clients derived significant value to their companies and individuals regardless of whether the individual was called for interview by the FSA.
An established corporation, entering the financial services industry for the first time, asked for Promontory’s assistance in preparing its Board and executive team members for potential FSA interviews. We were retained to interview each new appointment, providing feedback, and most importantly to the client, input on induction programs and group skills.
One of our existing clients was reassigning an existing executive to a new role. When initially interviewed by the FSA, approval was given subject to an intensive education program and re-interview. Promontory worked with the client to develop the education program, deliver components, identify providers for other components, and hold a practice interview complete with feedback.

Preparation of Senior Staff for Regulatory Approval

Representative Engagements

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