On March 8, the UK Financial Conduct Authority (FCA) published a policy statement on a new directory of financial services workers (Directory). This follows the FCA’s proposals to introduce the Directory and amend the existing financial services register (FS Register) in its consultation paper of July 2018 (as reported in the Corporate & Financial Weekly Digest edition of July 13, 2018).
In its policy statement, the FCA notes that it has made changes to the proposals it had set out in its consultation paper, such as including information on individuals’ membership of accredited bodies and extending the deadline for firms to update information. The FCA also explains that it is including a health warning on the Directory to highlight where information may be out of date, which will make information more easily accessible and understandable. The FCA will allow firms to submit multiple records at once with sufficient time ahead of the submission deadline if they have many individuals whose relevant information will be made public on the Directory (Directory Persons).
The new Directory also will include individuals performing roles that will no longer be made public on the FS Register, once the senior managers and certification regime (SM&CR) is extended to all UK firms regulated by the FCA (Solo-Regulated Firms). The FS Register will continue to be available to the public following the extension of the SM&CR, but will include fewer individuals, as only individuals for specified senior manager roles approved by the FCA and/ or the Prudential Regulation Authority (PRA) will appear on the FS Register.
The final rules establishing the Directory are set out in the Reporting of Information About Directory Persons (Dual-Regulated Firms) Instrument 2019 and will go into effect on September 9. The deadline for uploading information to the Directory for banking firms and their appointed representatives is March 9, 2020, and the deadline for Solo-Regulated Firms is December 9, 2020 (i.e., 12 months from the date on which SM&CR will commence for those firms).
The Directory interface will go live for banking firms and insurers in March 2020, shortly after information on their Directory Persons has been uploaded, and in December 2020 for all other firms’ Directory Persons.
The FCA’s policy statement is available here.