Recommendation 85

Witnesses emphasised the delays and frictions firms face due to the slow authorisation of senior managers. The Association of Foreign Banks told us that, in the SM&CR, “authorisation processes are too onerous and frequently still require too long to receive approval, especially compared to other financial centres. This deters foreign banks from recruiting for, and expanding in, the UK.” 144 The Association of Foreign Banks suggested that some international executives were reluctant to locate in the UK due to the SM&CR regime: “Some banks have also voiced that there is reluctance from senior individuals based overseas to take SMF [senior management functions] positions in the UK, again due to the regime’s complexity and disincentives … which reduces the international talent pool available to banks in the UK.” 145