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BSB consultation: Good practice guidance on regulatory references

On 30 January 2019 the Banking Standards Board (BSB) launched a consultation on its proposed good practice guidance on regulatory references, a core element of the Senior Managers and Certification Regime.

The consultation will run for seven weeks until 20 March 2019. The BSB would welcome views from all interested parties, and in particular from firms that are required to provide and obtain regulatory references (particularly those operating in the banking sector), and individuals subject to the Certification Regime or those representing them.

The guidance has been developed in partnership with member firms through the BSB’s cross-industry Certification Regime Working Group (CRWG). It reflects a pooling of industry knowledge and experience and is intended to help firms implement the regulatory requirements effectively.

The guidance outlines three high-level principles which consider both the ‘providing’ and ‘receiving’ ends of the process, and state that regulatory reference practices and policies should be:

fair to the individuals about whom they are written without compromising the integrity of the reference, and in the way that they are used by firms when recruiting individuals;

proportionate in relation to other firms and individuals when fulfilling regulatory reference requirements, in particular by taking reasonable steps to identify and verify relevant information, and when considering issues raised by regulatory references and updates; and

consistent in the way that individuals are treated by firms providing and receiving references; with other processes and policies within a firm; and, as far as possible, between firms in the quality and quantity of information included. This should not preclude, especially in the early period of regulatory references implementation, learning from honest mistakes and changing course to address them.

BSB good practice guidance allows member firms and others in the sector to reference their own policies and procedures against a statement of what ‘good’ looks like. It does not impose any legal or regulatory obligations on BSB members, nor does it replace regulation. In the event of inconsistency, applicable laws, rules and regulations prevail.

Banking Standards Board Consultation – Certification Regime: Regulatory References 

Draft Guidance Banking Standards Board Consultation – Certification Regime: Regulatory References

Senior Managers and Certification Regime

Exploring how the SMCR - and especially Certification - can be implemented in the most effective way across the sector.

The Senior Managers and Certification Regime is a major regulatory change that will affect all banks and building societies. Responding to recommendations by the Parliamentary Commission on Banking Standards, the government and regulators have together developed a comprehensive framework to ensure better accountability and responsibility for behaviour, competence and culture in banks and building societies. The new framework provides an opportunity for the industry to focus on and demonstrate a culture of professionalism. We are working with firms and regulators to facilitate this, including areas where a common approach across firms could support both the objectives of the regime and the skills and development of the people covered by it.


Evaluating whether a more 'professional' approach to banking would improve behaviour and competence across the industry.

The Parliamentary Commission on Banking Standards found that 'banking culture has all too often been characterised by an absence of any sense of collective responsibility to uphold the reputation of the industry', and argued that a greater focus on professionalism could be an answer to this. Working with a leading team at the University of Leeds, we are researching the issues around professionalism in banking. In particular, we are reviewing how professional qualifications are currently used across the sector, and at whether a stronger role for professional bodies, along the lines seen in some other sectors, like medicine or law, would help raise standards. To inform this work and develop a rounded picture of 'professionalism' and what it means in banking, we are surveying banks and building societies, professional bodies and a wide range of other interested groups, including consumer bodies and investors.


Providing an honest and impartial assessment to Boards of progress against objectives on behaviour, competence and culture.

The BSB assessment exercise presents Boards with an objective and impartial view of their firm's culture, identifying where things are working well and recommending areas for improvement. It draws on information not only from Boards and senior teams, but also from employees, investors (or members), trade unions, customer groups and other relevant bodies. In doing so, it will provide constructive challenge to each firm individually, while building a collective understanding of common issues across the industry, or sectors within it. We undertook our first annual assessment exercise in 2015 with ten firms (Barclays, Citi, HSBC Bank, Lloyds Banking Group, Metro Bank, Morgan Stanley International, Nationwide, RBS, Santander UK and Standard Chartered). The BSB itself will not publish individual assessment reports - each firm owns its own report - but key themes and messages will be set out in the BSB's annual report, the first of which will be published in Spring 2016. Given that Board engagement is central to the assessment work, only firms that have their headquarters in the UK are eligible for the full assessment exercise. All firms, including branches of firms headquartered overseas, will however be included in a focused membership-wide survey, which will allow each participating firm to benchmark itself against its peer group.



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