The final stage of recruitment under SMCR

Posted 20 July 2022 by Graeme Stewart

Since the introduction of the SM&CR, the process to recruit a financial adviser, and certify them as competent, has fallen squarely upon the regulated firm’s shoulders.  

In our three-part series we’ve looked at the key issues of both the recruitment and induction processes. Today we look at the final stage: updating the FCA Directory entry.

One of the key objectives of the FCA Directory was to give consumers and professionals the ability to check the details of key individuals working in financial services.

It’s therefore important that the FCA’s Directory shows all the staff within the firm that are subject to certification under the SM&CR.

In their latest guidance published in February 2021, the FCA stated ‘A person performing a function requiring qualification should be reported to the FCA as a Directory person even if they are training and are yet to receive a qualification.’

How to add a new adviser to the directory

Firms are reminded that they should be making relevant changes to the directory for all affected advisers (for example someone starting or ceasing an activity) within seven business days of that change. Failure to update within that time frame is likely to result in a £250 administration fee being levied on the firm by the FCA.

To add a new adviser to the firm’s directory information, a firm must log in to the FCA Connect system and add a Directory Person, via the ‘start an application’ function.

For newly qualified advisers (with no existing FRN number) additional information such as passport and National Insurance numbers will be required.

You will then input the details of the adviser, along with the advisory activities that they undertake.

For further information or support you may refer to the FCA User Guide : Adding or amending Directory Persons data for an individual

In summary

We find that firms forget about their directory entries when recruiting and so to avoid a potential £250 administration fee being incurred, we felt that this should play an important part in our series.

We hope our three-part guide to recruitment-induction and the FCA Directory has been useful and hopefully taken the edge off a headache that can be associated with the business of recruitment.

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Graeme Stewart

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Graeme Stewart