FCA and PRA skilled person reviews (s166)
Under section 166 of the Financial Services and Markets Act 2000, the UK Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA) have powers to require organizations to commission skilled person reviews into a particular issue or business area.
The consulting team at A&O Shearman comprises former senior UK regulators and senior financial services industry professionals with extensive experience in independent regulatory reviews across governance, individual accountability, culture, risk management, and control and conduct of business. Consulting by A&O Shearman is a member of the FCA and the PRA’s skilled person panels for:
- Governance, accountability, strategy, and culture
- Controls and risk management frameworks
- Conduct of business
We have worked on s166 reviews both in-house within regulated firms and as regulators. We understand the perspectives on both sides and how best to navigate the skilled person process for financial services organizations while meeting regulatory requirements and expectations.
Appointing a skilled person
If the FCA or the PRA has asked you to appoint a firm to undertake a s166 review, we can act as the skilled person across any of our areas of expertise.
Support through an s166 review
We also support our clients throughout the lifecycle of an s166 review. This can include providing strategic advice on engagement with the regulator and skilled person, giving project management advice on the scope of a review to optimize effectiveness and efficiency, helping to gather materials and draft information requests, or undertake remediation.
Across both options, we use our experience and knowledge as former senior regulators and as professionals within regulated firms to deliver practical and sustainable solutions and advice designed specifically for your business.
Independent third-party reviews
In addition to s166 reviews, we are also experienced and well-regarded in the undertaking of independent third-party reviews outside of the UK – including in Australia where we have conducted a range of independent expert reviews and compliance audits on behalf of key regulators such as APRA and ASIC.
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