FCA PS19/7 – The Directory

 In March 2019, the FCA published “The Directory”. Following on from the Senior Manager’s regime, there is a reduced number of people within a firm that are required to be approved by the FCA and PRA, and therefore a reduced number of individuals names will appear on the Financial Services register.

Consequently, those carrying out customer function type roles such as those who provide financial advice, help with pension transfers, traders, portfolio managers and additional directors will no longer be approved by the FCA and PRA and will not appear on the register. 

PS19/7 – The Directory seeks to address this, by establishing a new public register that would make this information publicly available. The Directory will also make the information that the FCA and PRA continue to approve available in a manner that is more accessible and user friendly, enabling users of The Directory to access and find information about all key individuals in a firm. 

The FCA propose to apply reporting provisions to The Directory so firms will have a responsibility to keep information on their staff up to date on an ongoing basis and will only have up to 7 business days to notify The Directory of joiners, leavers and changes in circumstances. Where a firm does not complete a confirmation of accuracy for their submitted data, or in cases of late or inaccurate data submissions, an administrative fine of £250 may be levied against the firm by the FCA.  

In order to allow for all firm’s data to be aligned in accordance with their relative SM&CR requirements, The Directory data will not be made public until March 2020. However, those roles that the FCA and PRA will no longer approve will be removed from the register in December 2019 and they must be on The Directory by either March 2020 (Banking and Insurance) or December 2020 (the rest), so the people conducting these roles could be “invisible” for up to either 3 or 12 months.