The FCA has introduced a new Form A for Senior Manager Function (“SMF”) and Controlled Function (“CF”) applications (the latter applicable to appointed representatives) and has updated its webpage highlighting the changes. This is part of a wider review/update of its forms accessible via the Connect system and follows industry feedback. The FCA claims that the new Form A is quicker and easier to complete (although evidence to support this is thin on the ground).
The main changes are as follows:
New requirements:
Instead of submitting a CV, applicants will have to provide 10 years of employment history (double the current requirement).
New questions have been added on:
- The individual’s right to work in the UK;
- Any previous names shown on the Financial Services Register;
- The time to be spent by the applicant on activities related to the firm; and
- Time to be spent on external Directorships (where relevant).
Changes to functionality:
- The “send later” function has been removed (i.e. the option to delay submission);
- The Statement of Responsibilities has been integrated into the Form A, so a separate document is not required for this; and
- Virus scanning of attachments has been improved.
Other improvements:
- A checklist is provided of the information required to complete the application;
- Improved help and guidance; and
- Easier navigation and improved layout.
This new Form A is available for all standalone Form A applications – i.e. SMF or CF applications not related to authorisation applications, variations of permission or adding or amending appointed representatives). Form As for these other categories will be gradually updated to incorporate the new features.
The new Form A is effective and mandatory from 24 May 2024.
Cosegic comment: We assume the revised Form A is not unconnected to its Review of the Senior Managers and Certification Regime where the FCA/PRA proposals are still awaited – indeed one of the points raised in its Discussion Paper was how to improve the approval process for Senior Managers. However, it is not clear to us that the revised format represents a substantive improvement and arguably the obligation to account for a full 10 years of employment history is an added burden.
