FCA Directory Deadline – 31 March 2021

Solo-regulated firms need to complete their certification of their staff in compliance with the SM&CR and submit their Directory Persons data via Connect by 31 March 2021.

Directory Persons include:

• Directors who are not performing Senior Manager Functions (SMFs) – both executive and non-executive
• Other individuals who are sole traders or Appointed Representatives (including those within Appointed Representatives) where they are undertaking business with clients and require a qualification to do so
• All certified staff (those holding a certification function under the Senior Manager & Certification Regime - SM&CR)

If your assessment determines that no individuals in your firm fit the definition of a Directory Person, you will not be required to make a submission to the FCA.

Failing to submit required data in time is a breach of regulatory reporting requirements and could lead to enforcement or supervisory action. A £250 admin fee also applies for late / incorrect submissions.

We are well placed to support our clients in this area. Please contact Charlie Herbert or your usual Doyle Clayton contact to discuss how we can help you.