Today, the Financial Conduct Authority (FCA) launched a consultation (CP18/19) on a new Directory to help consumers and firms check the status and history of individuals working in financial services. The proposed Directory will include:

  • those who hold Senior Manager positions requiring FCA approval;
  • those whose roles require firms to certify that they are fit and proper under the Certification Regime;
  • non-Senior Manager Function (SMF) Directors; and
  • sole traders and appointed representatives where undertaking business requiring qualification in their capacity as an individual.

Many of these individuals do not currently appear in the FCA's Financial Services Register (FS Register) and, particularly in light of the extension of the Senior Managers and Certification Regime (SM&CR) to all firms, this has been a cause for concern by both the financial services industry and consumer groups; the Directory will plug this gap. In addition, the FCA plans to make changes to the FS Register (which will continue) to provide better access to the full record of information on authorised firms and the individuals it has approved.

The new Directory would:

  • make information public on additional individuals carrying out a wider range of roles (including those the FCA does not approve such as financial advisers, traders, portfolio managers and additional directors);
  • present information on these individuals, and the Senior Managers the FCA approves and who already appear on the FS Register, in a way that is more accessible and user friendly; and
  • enable users to find information on these individuals in a single public location.

Alongside the consultation paper, the FCA makes available a basic prototype version of the Directory. This is interactive so users can see how the Directory could work and leave feedback.

The FCA seeks feedback, by 5 October 2018, on:

  • which individuals to include on the Directory;
  • what information it should publish about each person; and
  • when firms need to submit and update information about their employees.

Following feedback, the FCA aims to publish final rules in the winter and complete system testing by summer 2019.

As firms would need to provide the FCA with information about individuals and more information about individuals will be made public, firms should consider the proposals and the prototype with a view to providing feedback to the FCA. In particular, under the proposals, firms will be responsible for ongoing timely (within one business day of a reportable event) and accurate reporting of information using Connect, including on the individual’s role, their unique identifiers, their workplace location and the types of business they are qualified to undertake. The deadline for dual-regulated firms to upload their data would be 10 December 2019 and for solo-regulated firms, 9 December 2020.