General counsels at FCA regulated firms will no doubt be relieved to see that in its latest Consultative Paper published yesterday the FCA has rowed back from its previous suggestion that "Head of Legal" should be a senior manager role within SMCR. As the FCA notes, so much of the Head of Legal's work relates to legal advice, the laws of legal privilege prevent it from using its powers over senior managers. If you would like to discuss this or any other changes being proposed by the FCA do please contact either Stuart Willey or Julia Smithers Excell.
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