FCA Quarterly Consultation – March 2020

Important Proposals Announced in FCA in Quarterly Consultation 27

On 6th March the FCA issued Quarterly Consultation 27, Consultation Paper CP20/4.

We will focus on Chapter 7 – “Clarify notification procedures, include guidance, and make changes to the Directory persons report”. We would like to draw your attention to the key points and proposals as they are specifically related to SMCR and the FCA Directory and will have an impact on your processes and data collection.

The consultation closes on 3rd April and we expect the final rules relatively shortly after that.

FCA Directory Persons Report Form

The CP confirms inclusion of and guidance on:

  • An optional ‘title’ field
  • A ‘commonly used name’ field (to be provided if known)
  • A ‘nationality’ field, which is mandatory where the firm provides a passport number
  • Additional or amended requirements around PRA certified functions and IDD and MCD responsibilities which are highlighted below.

Whilst not directly referred to it would seem likely that the FCA Multiple Submissions Template and Multiple Submissions Amend Template will need to be updated by the FCA to incorporate all the changes proposed in the Consultation.

Renaming the PRA Certified Function – Material Risk Taker

  • For the Directory Persons Report Form, the FCA propose to rename the PRA Material Risk Taker Certification Function from ‘[PRA CF] Material Risk Taker’ to ‘[PRA CF] Significant Risk Taker or Material Risk Taker’. This will ensure that the Directory includes persons who are only a significant risk taker; only a material risk taker; both a significant risk taker and a material risk taker thus aligning with PRA Certification scope.

Certified staff – IDD and MCD responsibility

  • The FCA are clarifying ambiguity about who can be allocated the Insurance Distribution Directive (IDD) activity and Mortgage Credit Directive (MCD) inter-mediation activity responsibility allocations and how this is notified to the FCA. This will be included in the FCA Handbook MIPRU (the Prudential Sourcebook for Mortgage and Home Finance Firms, and Insurance Intermediaries) as a notification rules and guidance.
  • These responsibilities are allocated to persons with sufficient seniority and authority in the firm and can therefore be allocated to a Senior Manager or Certified person holding a Significant Management Function. It is the firm’s responsibility to make the appropriate decision.
  • The FCA propose adding IDD and MCD responsibility boxes to the SUP 16 Annex 47AR Directory Persons Report in order to capture data where the responsibilities are allocated to Certified staff. This should also result in a change to the Directory Submissions Templates.

Minor changes to Form A (Long and Short) and Form E for Dual and Solo Regulated firms

  • Text relating to IDD and MCD responsibility allocation for SMF’s is being amended on Form A’s and E’s which will result in the publication of updated forms in FCA SUP10C. Refer to the examples in the Quarterly Consultation publication.


Useful references and links

Quarterly Consultation 27, Consultation Paper CP20/4.



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