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SMCR: Client dealing function CF30


The FCA has suggested changes to the client dealing function of the certification regime to render it very clear that the function is not aimed to apply to employees engaging with clients in a solely administrative role.

The proposed changes result from industry feedback that there was uncertainty whether or not such individuals could be regarded to be participating in “managing” or “arranging” activities and therefore snagged by the broadly worded scope of the client dealing function.

The FCA has recommended that the client dealing function will not apply to individuals performing a function that does not require them to exercise “a significant amount of discretion, judgment or technical skill”.
This would involve, for example, people who have exposure to clients but who are executing a purely administrative role and/or who have no scope to choose, decide or reach a judgement as to what should be carried out in a given situation, and whose tasks do not require them to exercise significant technical skill (including roles which are simple or largely automated).
The FCA has published a web-update clarifying that this proposed change relates to certain client dealing functions (rows (1 )( b), (2 )( b), (3) and (4) of SYSC 27.8.19) from now until commencement of the FCA’s revised rules.

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Lee Werrell Chartered FCSI FISM.
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