Following the implementation of the senior managers and certification regime (SM&CR), solo-regulated firms are now required to upload information on their advisers and other certified 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.
Post-SM&CR, the register has been reduced to only cover senior manager roles. This means all advisers and other certified roles now have to be added to the directory.
Advice firms must submit their data between now and 9 December 2020, with the data set to be published in December.
Before you start
First things first, to add someone to the directory there are several pieces of information you’ll need:
- The individual's full name and date of birth
- Their individual reference number (IRN), if they have one
- A list of all relevant roles they hold
- The start and end dates (if applicable) of each role
- What business the individual is qualified to undertake, for example, pension transfer specialist
- The postcode(s) where the individual is based (office address)
- The individual’s passport or national insurance (NI) number.
Most of the above information you or your HR team should have to hand.
How to use it
Once you have all the above, you then need to start adding it to the directory.
To complete a submission you’ll need to have a Connect account which is linked to your firm.
After you’re logged into Connect, you need to select ‘start an application’ > ‘directory persons’ > ‘start application’.
Completing the application can be divided into four sections:
1) Applicant details
2) Directory person details
3) Application involvement
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 then click ‘save and next’.
Directory person details - online form
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 then we’d 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 IRN, you’ll need to enter this along with their date of birth and either an NI number or passport number. The system will then be able to locate the member of staff and populate their known information on the form.
If they don’t have an IRN, then you’ll be asked to manually key their details.
Our top tips here are that if you’re usidng their NI number as their unique identifier, you don’t then need to add in the nationality box.
Also, to make sure the correct format is used, the date of birth should be recorded using the calendar option on the right of the screen.
Directory person details - file upload
Due to banks and other institutions having a large number of people to add to the directory, the FCA has 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.
Our tops tips here are to be aware thatthe system does not support commas, so it’s worth making sure these aren’t used anywhere in the file.
Also, don’tleave any blank rows in the file. If you do then any data below the blank row won’t be included in your submission.
Things to remember
- The file needs to be saved in a .csv format
- Make sure you use the same cell validations (for example, using a UK date format). If you use another format this may cause the submission to fail
- The maximum file size is 5MB
- The filename used for the file can’t have any spaces in it.
The full FCA user guide on how to complete the excel file can be found here.
Once this has been completed, it needs to be uploaded.
The disadvantage of this approach is there’s 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 and the most complex part of the directory. As such, there’s been some confusion among firms on 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 about15 roles from which you need to select those that are applicable.
Some of these roles come under the Prudential Regulation Authority (PRA) so can be ignored if you are solely regulated by the FCA.
The key ones here are ‘functions requiring qualifications’ such as pension transfer specialists and ‘manager of certification employees’, that is, 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 clients can engage with the member of staff, for example face-to-face, telephone or online.
The final screen in this section is the one which has caused the most confusion.
There’s a list of about 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.
Where you’re uncertain as to who should hold the role, you can cross-reference the role against the qualification requirements in appropriate qualification tables in the FCA handbook, 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 eventually search for advisers near to them.
The only exception to this location requirement is where there’s a potential risk to the member of staff if their postcode is publicly disclosed, such as where someone is escaping abuse.
The final area in this section relates to the member of staff’s professional accreditation with third party bodies such the Chartered Insurance Institute or the Chartered Institute for Securities & Investment.
The final section is where the submitter needs to review all information completed and confirm it is accurate.
Once this is completed, you’ll then be able to submit the application.