FCA’s Directory list and the option for Bulk upload – deadline end of March

 It has been said that the FCA crack team of cybermen can make changing a light bulb a herculean task by opting to hold the bulb while we – the fee paying regulated community - maneuver the house around the light bulb.  And so it is with the FCA directory.  Fed up with years of abuse from IFAs about how inaccurate the register is, the FCA have switched the industry with responsibility for keeping it up to date – Sir Humphrey lives on!

 Firstly, if you have 1-4 persons, you should do this upload manually as its faster and easier and has a deadline of the end of the month. https://www.fca.org.uk/firms/directory-persons

 The spreadsheet only really comes into its own after 6-10+ people and I believe has an earlier cut off date as it will require a review process.

https://www.fca.org.uk/publication/systems-information/single-add-amend-user-guide.pdf - single

https://www.fca.org.uk/publication/documents/user-guide-multiple-add.pdf - bulk

 See the attached spreadsheet, and grit your teeth while I explain the 70 column spreadsheet that we have to wrestle with!   https://ifac.eu/download/get_file.php?download_id=WkZYd1k1R0x0OVBLcmtySXBmTGVKUT09

The explanation is held here….

 Its best to see this as a two- or three-part application that may apply to you only in part or in full depending on your role/s:

• 1.       Senior management responsibilities – “O” to “AX”
• 2.       Client Facing roles – “AY” to “CR”
• 3.       Acting as sole trader, AR individual to the firm “AY” to “CR”

Significant Management – Director or Senior manager/supervisor role.

• Ø  1-9 are FCA regulated roles and then the PRA equivalent positions (presumably if you are jointly regulated as FCA and PRA they both apply
• Ø  Choose from the dropdown list for “Role (1) and complete the start date; move to Role (2) and select from the dropdown another of the roles …. Until you have covered the management roles that are not client facing. If the person does not advise this will cover all that is required
• Ø  Typically for Investment firms you as the Director will have roles (4)(6)(7)(8) and (1) if you hold client funds.
• Ø  Typically for Mortgage firms you will be (4)(6)(7) and (1) if client funds are held.

Client Facing roles – Advisers, sole traders, and AR advisers:

• Ø  Client facing Investments, mortgage, Equity release advisers need to carry on doing “AY to CR” if they do not SM roles. Carry on if you are a Director that advises.
• Ø  If you are an adviser that is a sole trader (or self-employed/acting as AR) this is also “AY to CR”
• Ø  If you administer a contract for life insurance, you will need to include this in “BJ to CG”
• Ø  If your firm also handles administration relating to a life policy, then you need to add this too.
• Ø  Advising via an AR firm – the FCA would expect the adviser to be vetted under the principal firm’s certification process and thus should be reflected as and requiring qualification to advise for the principal firm.

After these you will need to add the place of work address and the accredited bodies – IFS;CII;CISI etc.

Finally …. If a date is out, a name misspelt, or an NI number a digit out …. The application will be returned for amendment.  So check this carefully.  

 Hope this makes it a little easier but if you are stuck - and you are a member - we are here to assist!

 Alastair.Frame@ifac.eu

 If you're submitting for fewer than 10 individuals, use our single user guide and submit by 31 March

  Or, if you're submitting for 10 or more individuals, use our multiple add and multiple amend guides and submit by 18 March