Changes to the list of PCFs
The Central Bank proposes a two-stage approach to the review of the PCF list. Firstly, an initial targeted revision of the PCF list as proposed in CP160. Secondly, a more substantive review to be coordinated throughout 2025 and 2026 with the planned three-year review of SEAR in 2027.
As part of the first initial revision of the PCF list, the Central Bank proposes to remove the sector-specific categorisations so that there will be one list of PCFs that applies to all regulated firms (other than credit unions). The proposed revised list, which is set out in the Annex to CP160, reduces the number of PCF roles from 59 to 45 by merging and renaming certain functions.
The Central Bank notes that the revised PCF list will not necessitate the appointment of new PCFs by regulated firms and that it will not impact existing approvals or applications in process. Where a role that was previously categorised for pre-approval only for certain industry sectors now becomes applicable to other sectors, the Central Bank will apply its in-situ process for any individuals occupying such a role at the time of the amendments to the PCF list. New appointments to any such role will be subject to the PCF approval process.
Of importance to note is that the new proposed PCF-45 Head of Safeguarding/Client Asset Oversight will apply to all regulated firms (other than credit unions), which previously only applied to investment firms/credit institutions and fund management companies.
Gatekeeper process
The F&P Gatekeeper Process Manual clarifies the stages of the F&P process, including the process that existing regulated entities and those seeking authorisation can expect from the Central Bank. In particular, the F&P Gatekeeper Process Manual provides for detailed information regarding the F&P interview process, including:
- Detailed invitations to interview;
- Commitment to 90-minute interviews;
- Panel members for interviews are selected on the basis of their qualifications and experience, ensuring these align with the regulated entity’s profile and the proposed role’s requirements;
- Provision of feedback after interviews;
- Cessation of “meet and greet” interviews as part of the F&P application assessment;
- Commitment to removing off record discussions with regulated entities on applications. Going forward the process will be that any discussions are on record; and
- Commitment to a 90-day timeframe for the F&P gatekeeping process.
Implementation report
The Implementation Report outlines the actions taken by the Central Bank to date in strengthening the F&P gatekeeping process against the recommendations in the Enria Report.
