SM&CR – The Last Piece of the Puzzle (Part 2)
In the first part of this series, we looked at requirements for assessing staff under the certification regime as being Fit & Proper, and how to certify them. Let’s look at the last part of this, updating the new FCA Directory.
SM&CR introduced the requirement to submit any certified or individuals that hold a significant harm function, onto its Directory. The aim is to help give confidence to the public and other professionals about the status of regulated advisers, particularly important now the FCA register only shows senior managers.
For those who have yet to complete this, you will need to gather the necessary information and verify its accuracy, before submission via the FCA Connect system. The Senior Manager with the Prescribed Responsibility for the ‘Certification Regime’ is the person who will be accountable for the accuracy of data on the Directory.
The data is required for certified persons requiring an F&P sign-off,
- Directors who are not Senior Managers,
- Senior Managers and Sole Traders who carry out a ‘function requiring a qualification’
- Appointed Representatives (ARs) who require a qualification to carry out their role, should all appear on the Directory.
Be aware that failure to keep the Directory up to date or inaccurate information, may result in a £250 administration fee.
The regulator is still allowing submissions up to 31 March 2021 but they will start to display data from firms as it is submitted from 14 December 2020. Again, while extensions are available, our guidance is to do this as soon as possible.
For the internal certifying process, you should be actively looking to assess the relevant people as fit and proper; it is such an essential component of your business. And, for your clients, and prospect clients, the sooner they can see you on the new Directory, the more confidence they will have in your business.