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SIMR requirements and deadlines for submitting Scope of Responsibilities forms

Governance, risk & compliance
FCA, Life insurance, Mutuals, Non-Life, PRA / Bank of England, SIMR, Solvency II

17 August 2016

As part of the Senior Insurance Managers Regime (SIMR) the Prudential Regulation Authority (PRA) has stated that the deadline for Solvency II firms and large non-Directive firms to submit their Scope of Responsibilities (SoRs) forms is Wednesday 7 September 2016. 

The key requirements for insurers submitting their SoRs forms are:

  • Relevant firms should complete a SoR form for each Senior Insurance Manager Function (SIMF) individual who was grandfathered across in the period leading up to 7 March 2016. These forms should reach the Prudential Regulation Authority by 7 September 2016.  This satisfies the PRA rule which can be found at PRA Rulebook / Key Function Holder Notifications / Rule 6.3.
  • All current key function holders who are also in a Financial Conduct Authority (FCA) Controlled Function are expected to provide to the PRA a completed SoR form by Wednesday 7 September 2016, if this has not already been done.
  • All current key function holders, other than "notified" non-executive directors; PRA SIMFs; or FCA Controlled Functions, are required to have provided a completed Form M to the PRA by Wednesday 7 September 2016.
  • Any notified non-executive directors who were appointed after 7 March 2016 should submit a Form M to the PRA as soon as reasonably practicable after appointment.
  • No further information is required from notified non-executive directors who were already in their post on 7 March 2016.
  • No information is required from small non-Directive firms at this time.

 Below is further guidance on the completion and submission of SoRs documents:

  • Between 1 January 2016 and 7 September 2016 firms should have been developing their Governance Maps.
  • An important part of the Governance Map is a signed Scope of Responsibilities Statement. Typically, this statement, we believe, can be comprehensively written to be no longer than two pages. This Statement must be signed by both the company and the individual.  It should be modified and re-signed when anything changes. 
  • Each statement must be stored for a minimum of 10 years, as part of the entire Governance Map, from the date of the final version issued.
  • By 7 September 2016 firms must submit the SoR form to the PRA and in sections 3.2.1 and 3.2.2 identify and/or precis the main content from the signed SoRs Statement. This ensures that the form submitted is a personalised reflection of the individual’s responsibilities.  If they wish, firms may decide not to include any additional information in the SoR form but we feel this may trigger further questioning from the regulator if only the bare minimum information is sent.
  • For smaller firms it should be sufficient to be succinct in the form. Should the regulator think firms have been too brief and challenge the submission, the form can be re-submitted with a full signed statement attached to it. 

How can OAC help?

If you would like help in constructing your SoRs, or if you would value an opinion on what you have done so far, our experts are ready to help.  

OAC's cloud-based solution for the SIMR comprehensively handles all requirements through logical workflows and a user friendly interface, including the Governance Map and recording of corporate information, so for more information see TRAC10 for SIMR.

Jackie Wright

For more information
Jackie Wright
Senior Regulatory Compliance Consultant

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