When the Senior Managers Regime was introduced the number of individuals listed on the Financial Services Register decreased. As a result the register no longer records all Credit Union Directors and only includes these registered under the Senior Manager Regime. The FCA plan to introduce a new Directory which will also record all Directors and those under the Certfication Regime in addition to Senior Managers. Policy Statement 19/7 was published in March 2019 and sets out the Regulators plans for the new register and details of who is to be included.
The Directory may help Credit Unions when contracting with banks and other third parties. Currently, it is difficult for banks to verify who are the Directors of a Credit Union. We have had an increasing number of requests from clients to assist with the verification process as a result. The new register may assist in this process.
Credit Unions though will only have 7 working days to report changes of circumstances, joiners and leavers and will therefore need to ensure they are setup to report in these timescales. The timescales are however better than the 1 day deadline that the FCA proposed last year.
Credit Unions have until 9 March 2020 to provide the FCA with the necessary information for the Directory. For more details on the register and details on how to upload your data please see the FCA webpage on the Directory.