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21 March 2020

The FCA published their advice to financial services firms to assist them in identifying key workers which fulfil roles which are necessary for dual-regulated or solo-regulated firms to continue to provide essential daily financial services to consumers or to ensure continued functioning of markets.

The regulator sets out that firms are best placed to decide which of their workers are essential and have set out the following steps to assist firms in identifying their key workers, firms should;

  • Identify the activities, services or operations which, if interrupted, could lead to the disruption of essential services to the real economy or financial stability.
  • Identify which workers are essential to support these functions.
  • Identify any critical outsource partners who are essential to the continued provision of services

The FCA set out that individuals which hold SMF1 function should ensure that only roles meeting a designated definition are identified as Key Workers.

The types of roles which the regulator set our that firms may consider as providing essential services are:

  • Individuals essential in the overall management of the firm, for example individuals captured by the Senior Managers Regime.
  • Individuals essential in the running of online services and processing.
  • Individuals essential in the running of branches and providing essential customer services, such as those dealing with consumer queries (including via call centres), client money and client assets and those maintaining access to cash and other payment services.
  • Individuals essential to the functioning of payments processing and of cash distribution services.
  • Individuals essential in facilitating corporate and retail lending and administrating the repayment of debt.
  • Individuals essential in the processing of claims and renewal of insurance.
  • Individuals essential in the operation of trading venues and other critical elements of market infrastructure.
  • Risk management, compliance, audit and other functions necessary to ensure the firm meets its customers’ needs and its obligations under the regulatory system.
    Any individual that provides essential support to allow the functioning of the above roles, such as finance and IT staff.

To read the regulator’s guidance please click here.

By Ian Beardmore

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