The Fitness and Probity Regime (F&P) was introduced by the Central Bank of Ireland (the “Central Bank”) under the Central Bank Reform Act 2010 (the “2010 Act”).
The Fitness and Probity Regime applies to persons in senior positions (referred to in the legislation as Controlled Functions (“CFs”) and Pre-Approval Controlled Functions (“PCFs”) within Regulated Financial Service Providers (“RFSP”).
The core function of the Fitness and Probity Regime is to ensure that persons in senior positions within RFSPs are competent and capable, honest, ethical, act with integrity and are financially sound.
In April 2019, the Central Bank issued a Dear CEO letter to Organisations. Included in this letter were concerns over Organisations’ understanding of the extent of their obligations under the Fitness and Probity Regime.
Considering this, Organisations were expected to review their policies, procedures, systems, controls and practices to address any shortcomings and ensure continued compliance with the Regime going forward.
Furthermore, as part of the Individual Accountability Framework, it is expected that the Central Bank will enhance the F&P requirements and has recently announced potentially including a number of new F&P roles (including CIO role, Head of Material Business Line and Head of Market Risk).
How we can help
KPMG can provide services to ensure the that both individuals in senior positions and the Organisations themselves are adequately prepared for the Fitness and Probity Regime and that they are well-appointed to maintain compliance with the Regime on an ongoing basis.
Examples of how KPMG can assist with this are:
- Interview preparation for PCFs who are awaiting approval from Central Bank.
- Provision of general fitness and probity advice.
- Preparation of senior personnel for compliance with the Fitness and Probity Regime.
- Design, implementation and on-going assurance of internal controls in place to ensure compliance with the Fitness and Probity Regime.
- Assist with on-going due diligence requirements as set out in the Fitness and Probity Regime.
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Co-Head of Consulting
KPMG in Ireland