Apportionment of responsibility

The FCA requires a firm to apportion significant responsibilities amongst its directors, senior managers or partners, so that it is clear:

• who has responsibility; and
• that the business affairs are adequately monitored and controlled.

The firm also needs to make and keep a record of these arrangements (e.g., by means of an organisation chart or responsibility matrix). These records need to be kept up to date and kept for six years from the date it was superseded by a newer version. An example firm Responsibility Matrix is included in the template section at the end of this chapter (SYSC Template 3).

Overall responsibility falls on the firm’s chief executive, senior partner or whoever assumes executive control. If this role is shared, then the responsibilities become jointly owned. If there is no chief executive or equivalent, then the responsibilities will fall on the individual managers and directors responsible for the management of the firm. With a smaller firm the business owner will become responsible for all or many of the functions.

The senior managers of the firm should be of sufficiently good repute and sufficiently experienced so as to ensure sound and prudent management of the firm.

Senior Manager responsibilities need to be formally documented in Statements of Responsibility as part of the Senior Managers and Certification Regime and are covered in the Supervision (SUP) section of this manual.