Context
Solo-regulated firms must submit their Directory Persons data via Connect by 31st March 2021.
Failure to provide the correct information on time would constitute a breach of regulatory reporting requirements. This could have severe consequences – including a £250 admin fee for late or incorrect submissions – and could lead to enforcement or supervisory action.
Key Points
- Directory persons are:
- An individual who is a Sole Trader who is undertaking business with clients and who requires a qualification to do so (e.g., a mortgage adviser – there is no qualification requirement in relation to insurance distribution).
- An individual who is an Appointed Representative of a firm that falls under the SM&CR (including an individual who works for such an AR) where that individual is undertaking business with clients and who requires a qualification to do so (there is no qualification requirement in relation to insurance distribution).
- Non-Executive Directors.
- Certified Staff – staff whom you have identified as Certified Staff under the Certification Regime and to whom you are issuing/have issued a Certificate as appropriate; or
- Any directors who are not currently SMFs
- The FCA has confirmed that due to the imminent deadline a potential high volume of submissions is expected, and it is envisaged that processing of some applications may take more than 24 hours. Firms are encouraged to submit their information early to avoid delays in the reflection of their data on the Register.
- Any notification messages on the possible outage will be added to Connect (‘Latest News’ section).
- Firms are requested not to contact the Supervision Hub on questions related to the submission of Directory Persons data.
- Guidance on how to submit Directory Persons data can be found here: https://www.fca.org.uk/publication/systems-information/single-add-amend-user-guide.pdf
Next actions
Firms should consider whether there are any individuals in the business who would be considered Directory Persons and, where Directory Persons are identified, should ensure that their details are submitted via Connect prior to the 31st March 2021 deadline.