The FCA has clarified that various systems and controls functions involving approval beneath the Approved Persons Regime (i.e. as the CF28 function) will be dealt with by certification functions under the SMCR.
The FCA has implied that this is only likely to affect Core and Limited Scope organisations (e.g. for limited scope and core firms who have a Chief Risk Officer, given the CRO is not a function that involves limited and core scope companies, the person will instead require certification under the significant management function).
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