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EisnerAmper Ireland | The Individual Accountability Framework | Financial Services Ireland

EisnerAmper Global

Individual Accountability Framework & SEAR

The Individual Accountability Framework (IAF), including the Senior Executive Accountability Regime (SEAR), is one of the most significant regulatory developments in recent years. IAF is intended to prioritise, strengthen and enhance individual accountability in the management and operation of firms regulated by the Central Bank of Ireland.  

The Framework is comprised of four parts: 

  1. SEAR: this will require in-scope firms to set out clearly and fully where responsibility and decision-making lie within the firm’s senior management.  
  2. Conduct Standards: Common Conduct Standards are basic standards such as acting with honesty and integrity, with due skill, care and diligence, and in the best interest of customers, and will apply to individuals in all regulated firms. Senior executives will also have Additional Conduct Standards related to running the part of the business for which they are responsible.  
  3. Enhancements to the current Fitness & Probity (F&P) Regime: This will include clarifying firms’ obligations to proactively certify that individuals carrying out certain specified functions are fit and proper. 
  4. Amendments to the Administrative Sanctions Procedure (ASP): The Central Bank of Ireland will have the ability to take enforcement action under the ASP directly against individuals for breaches of their obligations rather than only for their participation in breaches committed by a firm. 

 

 

Statement of Responsibility &  Management Responsibilities Map

In-scope firms are required to prepare a Management Responsibilities Map, which documents key management and governance arrangements including matters reserved for the board, terms of reference for key board committees and documenting key reporting lines.

Firms must also ensure that each PCF holder has a signed Statement of Responsibility which clearly outlines the PCF’s role and responsibilities. This Statement of Responsibility must be provided on request to the Central Bank of Ireland. 

How EisnerAmper can help 

Our dedicated Risk & Regulatory team is here to help you by providing advice, support and guidance on the implementation of SEAR. 

By partnering with EisnerAmper, we can support you with the preparation of the Statement of Responsibility and the Management Responsibilities Map. This results in an approach flexed to meet your needs.

  • Objective advice on responsibility mapping  
  • All business processes being captured and mapped  
  • Improvements to your firm’s governance structures and reporting lines 

In the meantime, our view is that there is much in the spirit of the SEAR that firms not initially falling within scope should recognise as aligned with good quality governance 

Derville Roland, Deputy Governor for Consumer and Investor Protection, Central Bank of Ireland in a speech to the Law Society of Ireland (April 2023). 

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