Until now, there has been little sign that the Senior Manager & Certification Regime - so far applied only to deposit takers and insurers - has damaged recruitment. But, with the FCA having just published plans to extend the regime to a further 47,000 firms, this report may be an early sign of the problem looming.
in truth it is still early days but here are 3 indicators to watch for:
1. Any impact from the first round of Enforcement cases on SM&CR (these will still be in the FCA's pipeline).
2. The regulators taking longer to approve senior appointments to firms, as the generation of executives who were grandfathered into the regime moves on.
3. The heat of debate around the FCA's consultation on its proposals to extend the regime to a much wider range of firms, many of which are very small.
This last was published at the end of July but its implications will only just be sinking in with many firms. The regulator has tried hard to be proportionate but its wriggle room is limited by Parliament and there is also pressure to be consistent in applying the regime's principles.
Rules aimed at making managers of financial companies more accountable for their conduct are hurting recruitment efforts, with some senior staff being reluctant to accept responsibilities that could make them liable for punishment.