Wed, Nov 11, 2020
The Directory, which was introduced under the Senior Managers and Certification Regime (SM&CR), is a new public register of individuals who carry out specific roles in UK financial service but are not Senior Managers and therefore not approved by the FCA. This includes individuals who are involved in regulatory activities, are customer facing, could cause significant harm to a firm and/or undertake significant back office functions. Individuals that need to be reported for the Directory, or Directory Persons, are:
Firms will be responsible for submitting data to the FCA on Directory Persons.
The Directory goes live on December 14, 2020 and to appear on this date, single entry submissions should be submitted by December 9, 2020. Data will be displayed incrementally as it is submitted by firms after this date. FCA solo regulated firms have until March 31, 2021 to submit their Directory Persons data via Connect if they use a single-entry submission form, but will need to submit earlier if using the multiple entry submission form.
The FCA webpage explaining the deadlines and time slots is here.
The Regulator has issued a guide on how to submit multiple entry submissions which can be found here.
We want to explain a point that has caused some confusion within the industry and has been recently clarified by the FCA—whether firms should notify the FCA of staff who were employed on December 9 2019 in Certified Functions, but have since left the firm and were not certified before doing so, as firms have until March 31 2021 to certify staff.
The FCA clarified that only individuals who have been certified within their firm need to be reported as Directory Persons. Therefore, firms will not need to report individuals who were in Certified Functions but had not been certified at the time of reporting.
Please also note that firms that cancel their permissions before March 31 do not need to submit Directory Persons data. However, if it is likely that a firm’s permission will not be cancelled by the FCA before March 31, the firm should prepare to submit any information required for Directory Persons.
Firms need to:
If you have any further questions or need assistance, please feel free to contact us.
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