He said: "It was originally drawn up with large financial services providers and banks in mind. It is of course important for all firms to understand who their most senior decision makers are and who is responsible for different functions within the business.
"In practice, all firms will be allocating responsibilities to senior managers already. The new rules will likely mean having to formalise and document these responsibilities."
Mr Bamford added: "IFA firms will have an extra task to complete, with the change from controlled functions to certified functions for advisers.
"This will shift the responsibility for approving individual advisers from the FCA to firms, who will need to certify their own people, making sure they remain fit and proper to perform their role at least once a year.
"In making this shift from controlled to certified functions, I hope that the FCA will continue to maintain a central register of approved advisers. There is a real danger in making this move to internal approval of individual advisers that scammers will take advantage of the lack of publicly available information."
Speaking at the Pimfa Wealth of Diversity Conference 2019 on Tuesday (February 5), Andrew Bailey, chief executive of the FCA, said: "There is no one size fits all solution and don’t believe anyone who tries to sell such a thing to you.
"We don’t prescribe what culture should be, that wouldn’t work. But we do pay a lot of attention to the outputs – the results of the culture at work – to see that harm is avoided – we look particularly at 4 drivers of behaviour – a firm’s purpose, leadership, approach to rewarding and managing people, and governance arrangements. And, to be clear, there is no rank order of these."