Further to the recent FCA communications reminding firms of the Directory Persons data submission deadline, it appears that some solo-regulated firms remain in danger of missing the 31 March deadline for submitting their Directory Persons data via the FCA’s Connect system.
Failure to provide the correct information on time would constitute a breach of regulatory reporting requirements. This could have severe consequences – including a £250 admin fee for late or incorrect submissions – and could lead to enforcement or supervisory action.
It seems some firms have not properly understood whose details they need to include in their submissions, and could fail to meet the deadline for that reason.
In particular some firms appear not to have understood that Directory Persons include non-executive directors – whether or not they perform Senior Manager Functions (SMFs).
The deadline for making multiple submissions has already come and gone. That happened on 18 March. Any submissions made between now and 31 March will therefore need to be done individually using the single-entry form. But they do need to be made!
The FCA has recently flagged up a number of reference points for firms still unsure about what they need to have done by when. These include its Guide for FCA solo-regulated firms, its web page on the Directory of certified and assessed persons, its single-entry user guide, and its list of commonly asked questions.
If you need help understanding or complying with these data submission requirements, please don’t hesitate to get in touch with a member of our expert team. You can contact us by calling 01925 767888, or emailing us at firstname.lastname@example.org