Directory Persons and the Financial Services Register
Directory Persons and the Financial Services Register

The following Financial Services guidance note provides comprehensive and up to date legal information covering:

  • Directory Persons and the Financial Services Register
  • Overview of Directory Persons
  • The Financial Services Register
  • The Directory: purpose
  • Directory Persons: statutory framework, rules and guidance
  • Directory Persons
  • Information published on Directory Persons
  • Practicalities—information reporting, transitional provisions and time frames
  • Where firms fail to submit information or submit inaccurate information

Overview of Directory Persons

As a consequence of the extension of the Senior Managers & Certification Regime (SM&CR) to solo-regulated firms in December 2019, the Financial Services Register (FS Register), the regulators’ record of authorised persons, was to be limited to information on regulated firms and Senior Management Function (SMF) holders. This was a significant change from the Approved Persons Regime under which the FCA approved, and maintained a register of, a broader portion of the financial services workforce. (From December 2019, the application of the APR is limited to appointed representatives and benchmark administrators that do not undertake regulated activities). In response to its proposals to extend the SM&CR, the FCA received ‘substantial feedback’ on the value of maintaining one central public record with information on SMF holders, and other key individuals in regulated firms, such as those holding SM&CR Certification Functions and those who undertake business with clients and require a qualification to do so. The FCA therefore announced the introduction of the Directory—a public register to provide a central location for information on Senior Managers and other key individuals, known as ‘Directory Persons’, at all FSMA-authorised firms across multiple sectors regulated by the FCA. This Practice Note provides an overview of the Directory Persons and the practical steps firms must take to comply with Directory Persons