Ireland’s IAF Bill Consultation Paper: what you need to know
The Central Bank of Ireland (CBI) issued the Consultation Paper on the Individual Accountability Framework, highlighting the importance of enhanced governance, performance and accountability for the industry.
Now that the CBI has reviewed the bill, organisations can finalise their implementation plans and policies, confident of the route ahead. The draft regulations and guidance provide clarity about the expectations for the implementation of; the SEAR, the Conduct Standards and the enhancements to the Fitness & Probity regime as well as amendments to the Administrative Sanctions Procedure (ASP)/enforcement action.
Much of the final consultation paper reflects preceding guidance and advice, holding firm the heart of positive outcomes and economic wellbeing, but there are several new requirements important for financial service organisations to integrate into implementation plans.
- Senior manager certification: Senior managers will now be required to provide a certificate annually – something that wasn’t included in the UK’s SM&CR regime. This will be alongside existing SEAR requirements for firms to set out clearly where responsibilities and decision-making lies.
- NED responsibilities: NEDs have been deemed “essential roles in the effective governance of firms”, and therefore have been brought under the scope of SEAR and given some additional prescribed responsibilities.
Ultimately, the integrity of the framework remains. The importance of clarifying individual accountabilities and responsibilities continues to be a resounding priority. Sound governance based on good practices and reasonable expectations, as this regulation relates to specific company structures, industries or requirements, is also fundamental. Encouragingly, the CBI note it has sought to “align with the way that firms have chosen to structure themselves” already, meaning the work done so far has been thoroughly worthwhile.
Throughout this process, the Trailight team has been configuring our platform to accommodate and systemise all the requirements set out by IAF and SEAR. Now the final regulation has been confirmed, we are swiftly reflecting on any changes or additional features that may need to be added.
Our system will be ready to support organisations to meet their individual regulatory compliance needs. We’re happy to discuss the implementation of IAF and how the Trailight platform will aid in the implementation and ongoing management of your regulatory needs.
Simply get in touch to discuss this with us or download the Trailight for IAF brochure below.