New Advisers and the FCA DirectoryIntroduction
Since I last wrote in February, we continue to be very busy helping you with all sorts of queries.
One question that has arisen quite often recently, is in respect of the recruitment of a new adviser, who holds a certification function under the Senior Managers & Certification Regime (SM&CR).
Paradigm provides a range of support including a recruitment checklist within the appendices of the Authorisation, Licensing, Supervision and Recruitment chapter of the manual. Here a firm will find step-by-step guidance on the recruitment process, which for certificate function now rests firmly with the firm under the SM&CR.
In addition, any new adviser will require robust supervision under the firm’s Training & Competence (T&C) plan. The firm’s T & C plan should outline the level and frequency of supervision to be applied to the new adviser and the path to be followed to their eventual competence assessment and certification.
The T & C plan should also show Induction process that a new adviser will follow.
Firms seeking guidance will find a risk-based T & C template, (which includes a template induction plan) within the appendices of the Training and Competence chapter of the manual.
The question that has been most frequent recently however is: how, and when do firms record the arrival of a new adviser in the FCA Directory detail pages?
The need to update the FCA Directory on appointment
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 is therefore important the FCA’s Directory show all the staff within the firm that require certification under the SM&CR.
In the original FCA guidance it was stated that only when adviser had been certified were they to appear within the directory. This was revised in the FCA guide published February 2021, when 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.”
When to add a new adviser to the Directory
Firms are reminded that they should be making relevant changes to the Directory (for example someone starting or ceasing an activity) within 7 business days of that change. Failure to update within that time frame and it is likely that a £250 administration fee will be levied by the FCA to the firm.
How to add a new adviser to the Directory
To add a new adviser to the Directory information, a firm must login to the Connect system and add a Directory Person, via the “start an application” function.
For newly qualified advisers (with no existing IRN number) additional information such as passport and National Insurance numbers will be required.
As Consultants we are asked how to add a newly qualified adviser to the Financial Services Register and we provide the following guidance.
The firm must log onto the Connect system and then choose the “ Start an Application” function. The firm will then choose the Directory Persons option – and from the three options available choose “Add Directory Person(s)”
The Connect system will ask does the individual hold an IRN (Individual Reference Number) and the answer to this question will be “No”
The system will then ask for information about the Individual and the firm can provide details of the adviser, including either their date of birth and National Insurance Number or Passport details and Country of residence. Paradigm recommends that Date of Birth and National Insurance number are used as passport details can change and this will make it difficult to amend details in the future.
The remaining information would be the same for an experienced adviser, Advisory Activities, Workplace Location and Accreditation
For further information or support you may refer to the FCA User Guide : Adding or amending Directory Persons data for an individual