Published online by Cambridge University Press: 03 December 2009
Evolution of FSA's approach
FSA's current approach to firms' infrastructure is a hybrid development from both banking and securities regulation. The former started with the 1987 Banking Act under which the licensed bank had to ‘conduct its business in a prudent manner’ and, for this purpose, ‘maintain … adequate systems of control … to enable the business to be prudently managed and comply with the duties imposed … under this Act’ and the Bank of England, as supervisor, had to ‘publish … a statement of the principles in accordance with which it is acting … in interpreting the[se] criteria’. Initially the Bank stated that ‘considerations include … management arrangements; … general strategy and objectives; planning arrangements; policies on accounting, lending and other exposures … and recruitment arrangements and training to ensure that the institution has … experienced and skilled staff … to carry out its activities in a prudent manner’.
However, by the mid-1990's, ‘internal control systems should provide reasonable assurance that:
(a) the business is planned and conducted in an orderly and prudent manner in adherence to established policies;
(b) transactions and commitments are entered into in accordance with management's … authority;
(c) management is able to safeguard the assets and control the liabilities of the business …
(d) the … records of the business provide complete, adequate and timely information;
(e) management is able to monitor on a regular and timely basis … the adequacy of … capital, liquidity [and] profitability …
(f) management is able to identify, regularly assess and … quantify … risks.
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