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Individual Accountability for Fund Managers

On 13 March 2023, following hot on the heels of facilitative legislation, the Central Bank published its long-promised individual accountability framework (IAF) for industry consultation.

Introduction of the IAF has been a key agenda item for the Central Bank since 2018 and, as the name suggests, it seeks to hold individuals accountable for their responsibilities in regulated firms.  The framework includes:

  • a senior executive accountability regime (SEAR) for banks, insurers and certain MiFID firms – fund managers are not therefore, in scope of the first wave of SEAR;
  • conduct standards for individuals in all regulated firms and firms themselves;
  • enhancements to the Fitness & Probity (F&P) regime relevant to all regulated firms; and
  • enhanced Central Bank powers of enforcement to ensure individuals’ and firms’ compliance with the IAF.

See our briefing here or the image below for further details and analysis of the key elements of the IAF relevant to fund managers.