The FCA and the PRA are extremely active providing advice to firms and consumers. On Friday 3 April, they issued a joint statement dealing with Senior Manager responsibilities and what happens if a Senior Manager is either furloughed or sick. A number of rules around prior notice to regulators and itemization of a change of Senior Managers' responsibilities are relaxed. It is made clear that the regulators expect Senior Managers with responsibility for compliance and the MLRO to be furloughed "as a last resort" and that there should always be an active Senior Manager(s) with responsibility for business continuity, cybersecurity and outsourcing.
The FCA appears, thankfully, to have rolled-back on the position it was taking at the beginning of last week that firms should temporarily cease business lines which cannot be undertaken with all relevant staff working from home. This does come with the caveat however that the FCA does expect "business as usual" monitoring and surveillance to be able to be undertaken without relevant back- and front-office staff needing to be in the office or disaster recovery site.
We must maintain a watching brief on this situation, as must the FCA and the PRA.
Joint FCA and PRA statement Senior Managers and Certification Regime (SM&CR) and coronavirus (Covid-19)