Key workers in Financial Services

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24 March 2020

The FCA has issued a communication for firms to help identify who the key workers are.    Their definition is:

A key financial worker at a dual-regulated, FCA solo-regulated firm or PSR-regulated firm, or operators of financial market infrastructure, fulfils a role which is necessary for the firm to continue to provide essential daily financial services to consumers, or to ensure the continued functioning of markets.

With a communication stating all complaints should be responded to promptly and aim to resolve complaints within 8 weeks.  If firms aren’t able to they should consult with the regulator.

SO who are the Key Workers

The regulator states that the Chief Executive Officers SMF1 is accountable for ensuring adequate process so that only roles meeting the definition are designated. For firms that do not have an SMF1 Chief Executive Officer, this will be the most relevant member of the senior management team.

The types of roles that may be considered as providing essential services could be:

  • Individuals essential in the overall management of the firm, for example, individuals captured by the Senior Managers Regime.
  • Risk management, compliance, audit and other functions necessary to ensure the firm meets its customers’ needs and its obligations under the regulatory system.
  • 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 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.
  • Any individual that provides essential support to allow the functioning of the above roles, such as finance and IT staff.

If any firms are unable to perform their regulatory duties you are reminded to discuss this with the FCA in the first instance.

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