Preparing for Fitness and Probity interviews

Under the Central Bank of Ireland (CBI) Fitness and Probity (F&P) regime, the CBI assesses the suitability and competence of individuals who apply for senior roles in regulated firms. These are referred to as 'Pre-Approval Controlled Functions’ or PCFs.

There are several stages to go through before approval is granted and candidates can formally take up the proposed role. These include:

  • Completion of the firm’s own recruitment and due diligence process.
  • Submission of an individual questionnaire (IQ) and relevant supporting documents e.g. CV and proof of educational qualifications.
  • Desk-based assessment by CBI (obtaining information, seeking responses to follow-up queries, clarifying inconsistencies and completing background checks).

Once the CBI desk review is complete, for many applicants that is the end of the process and approval is given. However, it is becoming increasingly common that the CBI requires individuals to attend an interview to outline their experience and suitability for the role.

PCF interviews are almost standard practice for positions at firms with a high Prism rating (and often medium-high ratings) but can be requested for any individual seeking approval. If an individual was employed by a firm where there has been an enforcement action, it increases the likelihood of being called for an interview. Interviews are typically held in person at CBI offices.

There are two types of CBI Fitness and Probity interviews: Specific and Assessment.

Assessment Interviews

Assessment interviews are the most common and take between one and two hours to complete. It focuses on the applicant’s relevant experience, skills, understanding of the industry and role they are applying for. Any regulatory issues during previous employment will be discussed to assess the applicant’s level of involvement.

The interview panel is made up of members of the hiring firm’s supervision team and a note taker is present. Invitation to attend is relatively informal and issued without invoking the statutory power of the CBI to request the attendance of the applicant.

Despite the informal nature of the invitation, applicants should fully prepare for these interviews. For example:

  • Be familiar with your CV and employment history.
  • Review the research completed on the proposing firm when applying for the role.
  • Refresh your awareness of the industry, firm, group (if applicable), the regulatory framework relevant to the organisation and risks facing the firm and industry.
  • Review the CBI’s Fitness and Probity Interview Guide which outlines the process the CBI will follow.
  • Conduct a mock interview.

Following the interview, the CBI may approve the application or call the applicant for a ‘Specific interview’.

Specific Interviews

Specific interviews can be stand-alone or follow on from an assessment interview.  They are more in-depth and take place over one to two days.

The interview panel is usually comprised of members of the CBI enforcement division and the proposing firm’s supervision team. The process is quite formal and recorded by a stenographer. The notification to attend is a formal letter, invoking the CBIs statutory powers and advises that the applicant is entitled to be accompanied by a legal representative. In advance of specific interviews, the CBI will provide an agenda and reference materials which the CBI wish to discuss.

Specific interviews typically concentrate on agenda items, but the applicant’s experience and knowledge of the PCF position may be discussed.

Preparation for a specific interview should include the areas outlined above for an assessment interview, but it is advised to give particular attention to:

  • Agenda topics and reference materials.
  • Any compliance or other regulatory issues in previous employment that were disclosed in the IQ, including reviewing any public regulatory notices. 
  • Obtaining independent advice and support to prepare for such in-depth interviews.
  • Consider being accompanied by a legal representative.

Once the specific interview is complete, the CBI will either approve the application, request further information (and potentially a subsequent interview) or issue notification that they are “minded to refuse”.

For more information on Fitness and Probity requirements, PCF Assessments and ongoing compliance, visit the dedicated CBI webpage.

How Mazars can help with Fitness and Probity preparation

Our Prudential Risk team consists of ex-regulators and industry professionals who have significant experience in supporting individuals in senior positions and organisations themselves at every stage of the process, from candidate selection to interview preparation.

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