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News and views on topical issues

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20 Jul 2018

SMCR: the new kid on the block set to reinforce firms’ CASS oversight

The FCA published its Senior Managers and Certification Regime (SMCR) near final rules on 4th July 2018, which mainly confirms its proposed rules released last summer. In these new rules, the FCA has introduced a new Prescribed Responsibility for firms’ compliance with CASS which will require firms to reflect on the interaction of roles and responsibilities between the “CASS Prescribed Responsibility” (to be allocated to a Senior Manager) and the significant-harm “CASS Oversight function” (certified function).

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19 Jul 2018

California Consumer Privacy Act (AB 375), a GDPR Mini-me?

AB 375, adopted June 28, 2018, has many similarities to the EU General Data Protection Regulation (GDPR), effective May 2018, but also has some unique, stringent, regulatory obligations. It is not a complete mini-me of GDPR. AB 375 changes how businesses handle the personal information (PI) of California residents, and is the toughest US privacy law enacted in any state. Firms complying with GDPR should not assume they will be compliant with AB 375 without further analysis and business process re-engineering.    

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12 Jul 2018

SMCR – The countdown has started

On 4th July, the FCA finally published a policy statement (PS18/14) containing feedback and the near final rules on the extension of the Senior Managers & Certification Regime (SMCR) to FCA solo-regulated firms.  The FCA also confirmed that SMCR will be extended to FCA solo-regulated firms from 9th December 2019, following the roll-out to insurers on 10th December 2018.

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10 Jul 2018

IBOR: The end is nigh

OK, it may not be truly apocalyptic but the financial industry is heading towards a seismic shift with the anticipated end of interbank offered rates (IBORs). IBORs are average rates at which certain banks could borrow in the interbank market and range in tenors from overnight to 12 months. These rates are referenced through a wide range of products including derivatives, bonds, loans, securitizations and deposits, which are used by a broad range of market participants from sophisticated investment banks to the regular home-owner.

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09 Jul 2018

Treasury Middle Office Operations: The missing link

In our last blog, we introduced the idea of a Treasury Middle Office Operations as a key component to the intraday liquidity management operating model. As a function, this group serves as the bridge between operations functions and Treasury, and allows interlock with lines of business, risk and finance functions on a day-to-day basis, enabling a coordinated and holistic approach to cash and securities management in line with Treasury’s strategic goals.

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