We have carefully considered this aspect upfront but also recognise the importance of ongoing review, as is currently under way in the UK. While the initial scope of SEAR will apply to approximately 150 firms, the Conduct Standards and enhancements to the F&P Regime and ASP procedures will apply to all regulated firms.
In the context of firms within the scope of the SEAR, there will inevitably be an increased, but necessary and proportionate, administrative burden during the implementation phase due to the requirement to prepare Statements of Responsibilities and the Management Responsibilities Map.