Senior Insurance Managers Regime - Searchlight Insurance Training

Senior Insurance Managers Regime

On 13 August 2015 a significant milestone was reached in the implementation of the Senior Insurance Managers Regime (SIMR) with the publication of final rules and guidance. These set out the PRA’s requirements of the standard of behaviour expected of those in positions of responsibility at regulated insurance firms.

The new regime has major implications for Solvency 2 firms, although solo-regulated (FCA) non-Solvency 2 firms will also see changes to the existing Approved Persons regime at the same time.

Timeframes are tight, with firms being required to start preparing themselves to enter the new regime in January 2016, with a number of tasks needing to be fulfilled before, or in the first months of, the new year.

This one-day workshop will help to set the new regime and its requirements in context and will assist firms in understanding what they have to do and by when. For those needing more practical assistance, the workshop provides a foundation which we can help you build on through our ‘SIMR Readiness Programme’, tailored to meet your specific requirements.

Delegates may  opt to attend the morning only for an overview, or the full day for a discussion of the implication for their own business.



Duration: 1 day(s) CII CPD Hours: 6

Morning Session 09:30-12:30

Background and Introduction:

  • Brief overview / reminder of the Approved Persons regime as it stands prior to January 2016
  • How we arrived at this point – the emergence of SIMR and key drivers for change (Solvency 2 etc.)
  • Brief comparison of the new and old regimes
  • Implications for businesses – Solvency 2 & non-Solvency 2

Technical Detail:

What’s changing?

  • The introduction of ‘Prescribed Responsibilities’
  • The move to PRA’s ‘Senior Insurance Management Functions’, ‘Key Function Holders’ and ‘Persons working within Key Functions’ regime
  • The production and maintenance of ‘Governance Maps’
  • Further evolution of FCA’s ‘Controlled Functions’ regime
  • How the regimes interact where they need to
  • Conduct Standards – PRA and FCA

Who will be affected?

  • Those currently holding Approved Person status – dual regulated
  • Those currently holding Approved Person status – FCA only
  • Those who are not currently Approved Persons but who will be ‘Key Function Holders’ in the PRA regime
  • The implications for Non-Executive Directors and the role of the ‘Senior Independent Director’

How to prepare?

  • Transition and the ‘grandfathering process’ – how it works and timescales
  • New applications – how they should be completed and by when
  • Training and competence – the role of T&C in achieving compliance

Governance Maps

  • What are they?
  • What do they do?
  • What do they look like?
  • How to prepare a governance map

When does all this happen?

  • Timelines – the need for speed!

Afternoon Session (Optional) 13:30-16:30

Delegates to consider in more detail the implications of the new regime for their own businesses.

Facilitated session to cover:

  • Questions and concerns from the morning session
  • Quick-fire gap analysis
  • Preparing individual next steps:
    • What do I need to do next?
    • What questions do I need answers to from the business?
    • Who are my key stakeholders?
    • How do I get the support I need from these key stakeholders?
    • Who else do I need to be engaged and involved?
    • How should I communicate this internally, to whom and by when?
    • What support do I need from outside the business?
    • What are my key actions and when do I need to complete these by?



Follow on Consultancy and Training

Our one day ‘Foundation Course’ is supported by our *SIMR Readiness Programme* which provides consultancy and training tailored to fit the individual client’s requirements

The suggested content below is tailored to each client’s needs:

  • Review of client’s current Approved Person arrangements and how these map over to SIMR
  • Identification of SIMFs, Key Function Holders and CFs – identifying gaps and omissions
  • Training to client’s Board, Senior Management team and other Key Function Holders on new PRA / FCA regimes
  • Facilitation of client’s Board effectiveness review
  • Advice on preparation of client-specific governance maps
  • Assisting clients to prepare required forms (grandfathering and new applications) prior to submission