Senior Executive Accountability Regime
The Central Bank and other international regulators have been prioritising ‘individual accountability’ for several years.
The proposals to introduce a ‘Senior Executive Accountability Regime’ (‘SEAR’) in Ireland are a significant step in that development.
The SEAR will interact with other Central Bank reforms to the current Fitness and Probity and Enforcement processes.
These reforms will enhance the regulator’s ability to hold individuals to account when regulatory contraventions occur in the business area for which they are responsible. They will also provide additional scrutiny in both the regulator’s and firms’ assessment of the ‘fitness and probity’ of individuals.
The SEAR will require firms to review and overhaul their senior management arrangements, governance and HR processes.
This reform provides firms with an opportunity to take stock of these frameworks and improve the clarity, understanding and operation of individuals’, committees’ and teams’ roles and responsibilities within their organisation.
SEAR: Practical Steps to Prepare Now
Patrick Brandt, Partner, Financial Regulation looks at what can you can do now to prepare for SEAR and what you should leave until the proposals are clearer.