While offering guidance on which financial services workers could be considered essential, the UK Financial Conduct Authority says that firms themselves are best placed to make those decisions.
The United Kingdom’s Financial Conduct Authority (FCA) on 20 March 2020, published steps that regulated firms should take to help identify key workers in financial services. The FCA begins its advice by setting the issue squarely within the wider framework of the UK government’s advice published the day before on maintaining educational provision.
The UK government has closed schools for the most part but is asking schools to continue to provide care not only for vulnerable children but also for a limited number of children whose parents are critical to the coronavirus (COVID-19) response, which includes parents working in the financial services sector whose children cannot be safely cared for at home. The FCA points out that this category includes parents who work in financial services and are needed for the provision of essential financial services which it labels as “key financial workers”.
The FCA explains that a “key financial worker” at a dual-regulated firm (for example, a bank, investment bank, or insurer regulated by the FCA and Prudential Regulation Authority), the FCA solo-regulated firm, or payment services regulated firm, or at an operator of financial market infrastructure, fulfils a necessary role for the firm/operator to continue to provide essential daily financial services to consumers, or to ensure the continued functioning of markets.
Here are the FCAs’ rules of thumb:
By way of example, the FCA enumerates the types of roles that may be considered as providing essential services as follows:
The FCA expects only a limited number of people to be identified as being “key financial workers.”
The FCA asks firms to consider whether they should issue a letter to all individuals they identify as key workers that clearly identifies them as such and that can be presented to schools on request, recommending that the letter includes the sentence "the individual has been designated as a key worker in relation to their employment by [firm name]” and is signed by someone with appropriate authority. Firms should continue to follow UK government guidance on COVID-19 closely and take the recommended steps.
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