Following the implementation of SM&CR, solo regulated firms are now required to upload their advisers and other certified members of staff to the new FCA Directory.
Before SM&CR, the register was the depository for everything to do with a regulated firm including detailed information about a firm’s advisers. With the introduction of SM&CR, the register has now been reduced to only contain Senior Manager roles. This means that all advisers and other certified roles have now been to be added to the Directory.
For more information about the Directory, please see our previous blog.
First things first, to add someone to the Directory there are several pieces of information which you will need:
Most of the above information you, or your HR team, should have to hand.
Once you have all the above information, you then need to start adding it to the Directory.
To complete a submission to the Directory you will need to have a connect account which is linked to your firm. After you are logged in to Connect you need to select “Start an Application”, “Directory Persons” and then “Start Application”.
Completing the actual application can be divided into four sections:
These are the details of the person completing the submission and are pulled through from your Connect account (so hopefully these should all be correct). As such, all you need to do with this section is double-check it and then click the “save and next” button.
There are two ways of uploading information to the Directory, you can either upload an excel file or you can complete the online form.
There are advantages and disadvantages to both approaches – if you have a lot of people to add you may find it easier to use the file upload option. If you have limited information available/not many people to add or are not that confident with excel/file uploads then we would recommend using the online form.
In our opinion, the online form is a lot easier to use and reduces the potential risks of excel fat finger submissions.
Where the member of staff has an Individual Reference Number (IRN), you will need to enter this along with their date of birth and either a National Insurance Number or Passport Number. The system will then be able to locate the member of staff and populate the known information about them on the form.
If the member of staff does not have an IRN, then you will be asked to manually key their details into the form.
Top tip: If you are using the National Insurance Number as the unique identifier please DO NOT add in the Nationality box.
Top tip: The Date of Birth must be recorded using the calendar option (on the right of the screen) to ensure that the correct format is used.
Owing to the banks and other institutions having a large number of people which they need to add to the Directory, the FCA introduced a way to bulk upload.
The file is an excel file format and requires you to complete a proforma template with the required information in.
The file has several helpful column hints as to what needs adding into each column and there are even a few dropdowns to make life easier. There are however 97 columns which may need to be completed (depending on the role).
Top tip: The system does not support commas, please make sure that these are not used anywhere in the file.
Top tip: Do not leave any blank rows in the file, if you do so then any data below the blank row will not be included in your submission.
The full FCA user guide for how to complete the excel file can be found here.
Once this file has been completed it needs to be uploaded to the system.
The disadvantage of this approach is that there is no validation by the FCA before submission. Where a member of staff has an IRN, as mentioned previously, the system can cross-reference this against previous information to speed up and validate the online form before submission.
This is a four-step section which is the most complex section of the Directory and has caused several clients confusion concerning how to complete it.
The FCA ease you into this section with a simple question asking you to confirm which firm the member of staff needs to be associated with.
The next screen lists c.15 roles from which you need to select those that are applicable for the member of staff. Some of these are PRA roles (to cover those regulated by the PRA too) and as such can be ignored if you are solely regulated by the FCA. The key ones here are Functions requiring qualifications e.g. your Pension Transfer Specialist and Manager of Certification employees (e.g. the line manager of your certified staff).
Next to each role, there is a role started date box, for existing employees this date will always be 9 December 2019. There is also a box to confirm how customers can engage with the member of staff e.g. Face to Face, Telephone or Online.
The final screen in this section is the area which has caused the most confusion. There is a list of c.23 activities, where an individual needs to have a specific qualification. This includes, for example, mortgage advisers, retail investment advisers and pension transfer specialists. A majority of these are self-explanatory, such as 11. Pension Transfer Specialist. Where you are uncertain as to who should hold the role, you can cross-reference the role against the qualification requirements in TC App 4.1. which can be found here.
The third step relates to the location of the member of staff. For this section, you need to confirm the postcode(s) where the member of staff is located. This is so that members of the public can search for advisers etc. near to their location.
The only exception to this location requirement is where there is a potential risk to the member of staff if their postcode is publicly disclosed e.g. where someone is escaping abuse.
The final area in this section relates to the member of staff’s professional accreditation with third party bodies i.e. The CII, CISI etc.
The final section is where the submitter needs to review all information completed and confirm that it is accurate.
Once this declaration is completed, you will then be able to submit the application.