The deadline for solo-regulated firms to submit their data via Connect to the Directory of Certified and Assessed Persons using the single entry submission form is 31 March 2021.
The online Directory will include details of:
- Individuals designated as Certified Staff under the Senior Managers and Certification Regime (SMCR);
- Non-Executive Directors (NEDs) who have not been designated as Senior Managers under SMCR; and
- Certain other individuals in customer facing roles such as, financial advisers, sole traders, or appointed representative.
The FCA’s Policy Statement (PS19/7) provides useful background regarding certified and assessed persons as well as information necessary for preparing a submission. Page 5 includes a full list of all the certified and assessed persons information that will appear publicly on the Financial Services Register.
Firms with more than 10 directory persons (including, potentially, some appointed representatives) are able to submit all data in one upload using the multiple add submission form.
Firms that have not been already contacted by the FCA about a specific time slot for upload but want to use this multiple add template submission method, will be required to submit between 26 November and 4 December 2020 or between 11 January and 18 March 2021. The single submission form can be used to submit any time up to the deadline of 31 March 2021. If submissions are made before 9 December 2020 the data will appear on the register from mid-December 2020.
The multiple submission template initially appears very complicated with over 100 columns. However, we believe that the vast majority of investment firms, particularly those without retail clients, will realise that the form is relatively straightforward as it focuses on the personal details of the individual and their role “without customer engagement” (e.g. material risk data).
Points to remember when completing the multiple submissions form
- Each row represents a single directory person’s entry (individual) for a single legal entity. If an individual works for multiple legal entities, then a separate application needs to be submitted for each entity.
- The upload should be saved as a CSV UTF-8 file. Once converted to CSV UTF-8 any subsequent changes should be made to the original Excel file (.xlsx) and then converted back to a CSV UTF-8.
- Each certified and assessed person will require an FRN number and a start date for their particular role.
- The drop-down values in the template should be used with the correct cell formatting. Particular attention must be paid to dates, ensuring that Excel recognises them as dates rather than ‘general’ or ‘text’ (see the number format box in Excel).
- Commas and special characters are to be avoided in the template, as are blank spaces in the national insurance field.
- It is important to use the latest version of the templates.
The FCA have produced a user guide to assist firms.
In addition …
- Remember to change the data within seven days of an employee leaving the firm, becoming certified or changing roles.
- The Directory Policy Statement, states that a £250 admin fee will be enforced where data is incorrect and has been identified by external users via a complaint to the FCA.
- Senior Managers who also perform a certified role need to appear on the register as such.
- The FCA expect staff included in the directory to have already been certified by the firm.
- Remember all non SMCR NEDs need to be added to the register.
If you have any difficulty with collecting the data or uploading it into Connect then please contact Dan, Simon, or one of the team at Objectivus.