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FCA Publishes Policy Statement on New Financial Services Directory

On March 8, the UK Financial Conduct Authority (FCA) published a policy statement on a new directory of financial services workers (Directory). This follows the FCA’s proposals to introduce the Directory and amend the existing financial services register (FS Register) in its consultation paper of July 2018 (as reported in the Corporate & Financial Weekly Digest edition of July 13, 2018).

In its policy statement, the FCA notes that it has made changes to the proposals it had set out in its consultation paper, such as including information on individuals’ membership of accredited bodies and extending the deadline for firms to update information. The FCA also explains that it is including a health warning on the Directory to highlight where information may be out of date, which will make information more easily accessible and understandable. The FCA will allow firms to submit multiple records at once with sufficient time ahead of the submission deadline if they have many individuals whose relevant information will be made public on the Directory (Directory Persons).

The new Directory also will include individuals performing roles that will no longer be made public on the FS Register, once the senior managers and certification regime (SM&CR) is extended to all UK firms regulated by the FCA (Solo-Regulated Firms). The FS Register will continue to be available to the public following the extension of the SM&CR, but will include fewer individuals, as only individuals for specified senior manager roles approved by the FCA and/ or the Prudential Regulation Authority (PRA) will appear on the FS Register.

The final rules establishing the Directory are set out in the Reporting of Information About Directory Persons (Dual-Regulated Firms) Instrument 2019 and will go into effect on September 9. The deadline for uploading information to the Directory for banking firms and their appointed representatives is March 9, 2020, and the deadline for Solo-Regulated Firms is December 9, 2020 (i.e., 12 months from the date on which SM&CR will commence for those firms).

The Directory interface will go live for banking firms and insurers in March 2020, shortly after information on their Directory Persons has been uploaded, and in December 2020 for all other firms’ Directory Persons.

The FCA’s policy statement is available here.

©2019 Katten Muchin Rosenman LLP

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John Ahern, Financial Attorney, London, Katten Law Firm
Partner

John Ahern, partner at Katten Muchin Rosenman UK LLP and head of the London Financial Services group, focuses his practice on banking, financial services, UK and European financial markets, and related regulations. His background in private practice and as in-house counsel at a global investment bank provides him with perspective on the unique regulatory issues facing the wholesale and private banking sectors. John advises multilateral trading facilities, broker-dealers and banks on trading, clearing and settlement as well as custody of securities—both physical and...

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Carolyn H. Jackson, International Attorney, Katten Muchin law firm
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Carolyn Jackson is a partner in Katten Muchin Rosenman UK LLP and is a Registered Foreign Lawyer. She provides US financial regulatory legal advice to a broad range of market participants, including commercial banks, investment banks, investment managers, broker-dealers, electronic trading platforms, clearinghouses, trade associations and over-the-counter derivatives service providers.

Carolyn guides clients in the structuring and offering of complex securities, commodities and derivatives transactions and in complying with US securities and commodities laws and regulations. 

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Nathaniel Lalone, Katten Muchin Law Firm, Financial Institutions Attorney
Senior Associate

Nathaniel Lalone, a partner at Katten Muchin Rosenman UK LLP, has a broad range of experience in the regulation of financial products and financial markets, and frequently provides regulatory and compliance advice to trading venues, clearing houses and buy-side firms active in the over-the-counter (OTC) derivatives, futures and securities markets. He is actively involved in advising clients on the implementation of MiFID 2 and MiFIR in the European Union as well as the international reach of US financial services regulation. He also has significant experience with structuring...

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Neil Robson, private equity fund managers counselor, Katten Law Firm, London
Partner

Neil Robson, a regulatory and compliance partner with Katten Muchin Rosenman LLP, focuses his practice on counseling hedge and private equity fund managers and other investment advisers on operational, regulatory and compliance issues. He regularly addresses Financial Conduct Authority (FCA) and EU authorization and compliance under both the EU Alternative Investment Fund Managers Directive (AIFM Directive) and MiFID, cross-border issues in the financial services sector, market abuse, anti-money laundering and regulatory capital requirements, formations and buyouts of...

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