Billy Bradley
Billy has significant contentious regulatory experience and advises financial services firms and senior individuals on governance, individual accountability and regulatory risk, with a particular focus on the Senior Managers & Certification Regime (SMCR).
He regularly advises on Conduct Rule breaches, fitness and propriety assessments, regulatory references and non-routine individual approval applications. Billy frequently engages with the FCA and PRA on behalf of clients, including responding to detailed regulatory information requests and preparing senior individuals for SMF interviews.
Billy has extensive experience supporting firms in the design, implementation and operation of the SMCR, including accountability mapping, governance frameworks and the practical application of individual accountability requirements at senior management and board level.
He also advises clients on FCA enforcement investigations, disciplinary proceedings, market abuse matters and whistleblowing investigations, as well as self-notification obligations arising from potential regulatory breaches. Billy supports clients in managing complex and sensitive supervisory relationships with regulators.
Practice Area
Panel
- Contributing Author
Experience
- CMS (2014 - Current)
Qualification
- LLB (2012)
Education
- University of Law (2012-2013)
- University of Southampton (2009-2012)
3 Contributions by Billy Bradley
PRACTICE NOTES
UK FCA/PRA SM&CR interviews for SMF approval: when used, focus areas, preparation guidance, including dual-regulated firms
SM&CR—SMF interviews for regulatory approval
This Practice Note sets out how the Financial Conduct Authority (FCA) and/or the Prudential Regulatory Authority (PRA) may deploy interviews as part of the approval process for those seeking to perform senior manager functions (SMFs) at authorised firms under the UK regulators’ Senior Managers & Certification Regime (SM&CR). It confirms that interviews are a discretionary tool within the SMF approval pathway and highlights when SMF candidates are most likely to be asked to attend. It also offers practical guidance for SMF candidates and their firms on preparing for interview, including frequent areas of focus, how the regulators approach external versus internal candidates, and additional points for candidates at dual-regulated firms.
This Practice Note should be read together with:
SM&CR Checklist—preparing for SMF interviews, which provides a practical framework to support candidates and firms in preparing across different SMF roles
SM&CR Checklist—SMF approvals: what to do when things go wrong, which helps candidates and firms identify, manage and respond to issues arising during or following an SMF interview, on receipt of a ‘minded to refuse’ letter, or where the
...
Financial Services
CHECKLISTS
FCA/PRA SMF Approval Interviews: SM&CR Preparation Checklist on Accountability, Governance, Risk, Culture, Consumer Duty and Form A (UK)
SM&CR Checklist—preparing for SMF interviews
This Checklist helps candidates get ready for interviews with the Financial Conduct Authority (FCA) and/or the Prudential Regulatory Authority (PRA) for approval to carry out a senior manager function (SMF) under the UK regulators’ Senior Managers & Certification Regime (SM&CR). Under the SM&CR, firms must seek regulatory approval when proposing to appoint someone to an SMF. During this process, the individual might be invited to interview by the regulators. Such interviews are run by a panel, featuring representatives from the regulators’ authorisations and supervisory teams. Interviews are not routine for every SMF application and, when arranged, are targeted by risk and tailored to the role. The scope and intensity of the questions will shift according to the SMF in scope, the firm’s risk profile, and the candidate’s experience. For instance, executive SMF interviews may lean more towards operational execution and decision-making, while interviews for non-executive positions (including Chairs) will typically emphasise oversight, governance, challenge and independence of judgement. In short, the interview approach is tailored, reflecting the role, the firm’s risks, and the individual’s background...
Financial Services
CHECKLISTS
SM&CR: Checklist for firms and candidates when SMF approvals go wrong—interviews, ‘minded to refuse’, refusals and next steps (FCA/PRA, UK)
SM&CR Checklist—SMF approvals: what to do when things go wrong
The Senior Managers & Certification Regime (SM&CR) obliges authorised firms to seek approval from the Financial Conduct Authority (FCA) and/or the Prudential Regulatory Authority (PRA) before appointing an individual to carry out a senior manager function (SMF). As part of that process, the regulator may invite the candidate to interview. Interviews are discretionary rather than a standard step in the SMF approval pathway.
This Checklist supports SMF candidates and their firms (which submit the SMF application on the candidate’s behalf) in spotting, managing and responding to issues that arise during an SMF interview or after it, including receipt of a ‘minded to refuse’ letter or a decision by the regulator(s) to refuse the application.
This Checklist should be read in conjunction with: SM&CR Checklist—preparing for SMF interviews and Practice Note: SM&CR—SMF interviews for regulatory approval.
What is meant by ‘things going wrong’?
Problems may emerge at several points during the interview process...
Financial Services
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