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In response to the Parliamentary Commission on Banking Standards (PCBS) report 'Banking for Good', in July 2014 the Prudential Regulation Authority (PRA) and Financial Conduct Authority (FCA) published a joint consultation paper ‘Strengthening Accountability in Banking: A New Regulatory Framework for Individuals’, outlining proposals for a new governance regime.
The most significant new measure is the introduction of a presumption of responsibility and reversal of the burden of proof for Senior Management. This will drive the need to look forward, anticipating and preventing breaches, rather than just backward, reacting to breaches only after they occur.
This practical guide, by Dechert LLP and the Forensic Risk Alliance (FRA) looks at which firms will be affected by the new regimes and what action they should be taking.