The Certification Regime covers specific functions that aren’t Senior Management Functions, but which have a significant impact on customers, the firm and/or market integrity – individuals are certified by the firm as fit and proper (at least annually).
Individuals in Certification Functions (CF) must be identified by 9 December 2019, but firms have a transition period of 12 months during which all assessment and certification must be completed. The full regime must be in place from 9 December 2020.
There are eight Certification Functions – those most likely to be relevant to Core firms are:
Expanded from current CF30 function – this applies to any person dealing in or arranging investments with clients;
- Anyone who supervises or manages a Certified Function … whether directly or indirectly, but who is not a Senior Manager. For example, if a firm employs a customer-facing financial adviser, every manager above the adviser in the same chain of responsibility will have to be certified (until the Senior Manager approved under the SMR is reached);
- Significant Management Function (current CF29)
This includes individuals with significant responsibility for a business unit – for example, this might apply to an Administration Manager.
*Client dealing function – clarification
The definition of client dealing is not intended to cover staff who operate purely in an administrative type role. Thus, the definition excludes any individual who has no scope to choose, decide or reach a judgement on what should be done in a given situation, and whose tasks do not require them to exercise significant skill.