Independent Directors must now be in place at all authorised fund managers (AFMs). They must comprise at least 25% of the Board, subject to a minimum of two. There can be no doubt that FCA will:

• Check to see that every AFM has at least the required number of NEDs on the Register;
• Challenge the independence of NEDs, especially where they have roles elsewhere in the group or have served for many years;
• Conduct a thematic review to test the effectiveness of Independent Directors within the context of their firm and Board and in relation to their direct responsibilities.

OWL is providing support to Independent Directors, to assist them to meet the expectations of the Regulator before they meet the Regulator.