MIC Checklist: What needs to be done post-submission?

Since the SFC published its circular and FAQs on the Manager-In-Charge of Core Functions (MIC) regime on 16 December 2016, we have issued three client alerts on the MIC regime. In this our fourth and final alert in the MIC series, we list out the various things licensed companies need to consider on an on-going basis after making the initial submission.

Checklist items

• Have you amended the compliance manual and any other relevant internal policies and procedures regarding the MIC regime?
• Have you set up a system for tracking changes to each MIC’s personal information?
• Has the company started tracking changes to the MIC-related information in the organisation chart?
• Have the MICs been incorporated into the internal compliance monitoring program?

Consider the effect on the MICs if there …

• is a new business line or consolidation of two business lines: how will this affect the MICs and the organisational chart?
• are promotions or resignations: how will this affect the MICs and the organisational chart?
• are new policies or procedures: how should senior management including the MICs be involved?

SFC notification events

Firms need to notify the SFC within seven business days if any of the information submitted to the SFC changes, such as:

• appointment of a new MIC
• cessation / resignation of an MIC
• an MIC becomes an MIC for an additional core function
• an MIC of multiple core functions gives up one core function to someone else
• addition / removal of a Key Business Line
• changes to an MIC’s personal information previously submitted to the SFC
• job title of someone to whom an MIC reports

Where a replacement MIC is being appointed, the SFC should be notified of the departure of the outgoing MIC within seven business days of the post being vacated and should be notified of the new MIC within seven business days of the new appointment.  You will need to provide information about the new MIC and an updated organisational chart at that stage.

If any of an MIC’s reports resign, there is no need to submit an updated organisational chart to the SFC, unless the person is not replaced or unless the job title of the replacement is different from that previously notified to the SFC.

As a reminder, the key dates for the implementation of the new regime are:

• 17 July 2017: Deadline for licensed corporations to submit MIC details
• 16 October 2017: Deadline for MICs who need to be approved as ROs to submit applications