The Financial Conduct Authority (FCA) set out steps firms should take to help identify key workers in financial services.
On 19 March 2020, the UK Government published guidance for schools, colleges and local authorities(link is external) on maintaining educational provision.
Schools are being asked to continue to provide care for a limited number of children whose parents are critical to the coronavirus (Covid-19) response and cannot be safely cared for at home. This includes parents who work in financial services and are needed for the provision of essential financial services (key financial workers).
A key financial worker at a dual-regulated, FCA solo-regulated firm or PSR-regulated firm, or operators of financial market infrastructure, 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 markets.
The government has asked parents to keep their children at home, wherever possible, and asked schools to remain open only for those children who absolutely need to attend. The regulator expect that only a limited number of people will be identified as being key financial workers.
The types of roles that may be considered as providing essential services could be:
- Individuals essential in the overall management of the firm, for example individuals captured by the Senior Managers Regime.
- Individuals essential in the running of online services and processing.
- Individuals essential in the running of branches and providing essential customer services, such as those dealing with consumer queries (including via call centres), client money and client assets and those maintaining access to cash and other payment services.
- Individuals essential to the functioning of payments processing and of cash distribution services.
- Individuals essential in facilitating corporate and retail lending and administrating the repayment of debt.
- Individuals essential in the processing of claims and renewal of insurance.
- Individuals essential in the operation of trading venues and other critical elements of market infrastructure.
- Risk management, compliance, audit and other functions necessary to ensure the firm meets its customers’ needs and its obligations under the regulatory system.
- Any individual that provides essential support to allow the functioning of the above roles, such as finance and IT staff.
Firms should 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.
The FCA further recommend 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 the Government’s guidance closely and take the recommended steps.