Governance
Improve SRA board-level oversight of regulatory risk and intelligence activity, through a clear reporting cycle which allows for the appropriate ‘escalation of risks’.
Ensure ‘consistent, accurate and timely’ records are kept of regulatory decisions.
Risk
Establish a framework for identifying risks to the consumer and public interests, including those arising from firm structures.
Collect market intelligence to assess risks arising from firm sales, mergers and acquisitions.
Share market intelligence and regulatory data effectively between internal teams.
Authorisation
Strengthen controls to…address the concentration of ownership, compliance [COLP/COFA] and management roles in one individual.
Client Money
Use a risk-based approach to assess the potential for consumer or market harm arising from firms’ financial stability, including obtaining and reviewing firms’ financial and accounting information.
Ensure firms have effective safeguards to protect client money.
Sales, mergers and acquisitions
Introduce oversight mechanisms for firm consolidation activity, including where relevant ensuring that the SRA receives advance notice of sale, merger or acquisition.
Use powers including for the inspection and provision of information, where the above presents or may present ‘serious risk to consumers’.
Pre-intervention
Improve capacity to intervene early and proportionately, including by ensuring that proportionate interim protections can be applied before formal intervention.
