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COVID-19: key financial workers

31 March 2020. Published by Rob Paine, Associate

The Financial Conduct Authority (FCA) has released guidance on steps financial services firms should take to help identify 'key workers'.

The guidance states that a 'key financial worker' is one who 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 the markets. Whilst much of the focus on key workers relates to the NHS or the food sector, key financial workers are required to ensure financial stability and continuity of service to consumers during the coronavirus pandemic. 

The FCA considers firms to be best placed to decide which staff are essential for the provision of financial services. Whilst a firm has flexibility to make its own assessment, the FCA expects key financial workers to include a limited number of people and recommends that the Chief Executive Officer Senior Management Function (SMF1) (or the most relevant member of the senior management team) is accountable for ensuring the firm has in place an adequate identification process. 

The guidance sets out a two-stage test of identifying:

  1. the activities, services or operations which, if interrupted, are likely to lead to the disruption of essential services to the real economy or financial stability; and
  2. individuals that are essential to support these functions.

The FCA considers that key financial workers might include, among others, persons essential for running branches and online services, processing payments, insurance claims and renewals and individuals in finance, IT, risk management, compliance and audit supporting those roles and ensuring the firm meets its customers' needs and regulatory obligations. It may also include individuals essential for the overall management of the firm, for example those within the Senior Managers Regime.

The guidance states that firms should consider issuing a letter to 'key financial workers' that can be presented to schools on request.

Read the new guidance here.