On 26 February 2018, the UK Financial Conduct Authority (FCA) issued a press release confirming that it intends to issue a consultation by summer 2018 on policy proposals to address feedback received from firms regarding the removal of a large swathe of the industry from the public Financial Services Register (FS Register).

The issue has arisen in the context of the proposals to extend the Senior Managers and Certification Regime (SMCR) (see FCA CP17/25, Individual Accountability: Extending the Senior Managers & Certification Regime to all FCA firms), whereby a large number of individuals currently pre-approved by the FCA will instead be approved by their firms, and as a result, will be removed from the FS Register.

However, in the press release, the FCA has confirmed that it received ‘substantial feedback on the public value of the FCA maintaining a central public record of certification employees and other important individuals in firms regulated by the FCA who will no longer appear on the FS Register. This includes non-executive directors, financial advisers, traders and portfolio managers.’

In our joint response to the FCA’s consultation on this issue, AIMA and the MFA asked the FCA to consider ways of maintaining a central record, if this can be achieved with a reasonable level of accuracy and without a significant administrative burden on firms. AIMA members are generally of the view that a central record in some form is beneficial, on the basis that this is an important centralised tool for initially verifying the employment history of new employees. We look forward to receiving further clarity from the FCA about the specifics of their policy proposals and will keep members updated on this issue.

If you have any questions, please contact Adele Rentsch or Adam Jacobs-Dean.