10th January 2017

Joint response to the FCA DP 16/4

The BBA has responded jointly with AFME to FCA’s discussion 16/4 paper  in relation how and why the legal function is currently captured under the Senior Managers and Certification Regime. Our response asserts that unique character of the legal advice given by in-house counsel to the Board and others, and importantly the protection of legal privilege, makes it different from other activities with which the bank engages. So we do not consider there to be any justification for requiring an individual to be personally accountable for the oversight of the legal function.

Please read the full response via the link below.