Individual registration - a review of the PIA's position

United Kingdom
Individual Registration - Sian Wakeling reviews the PIA's position

Each firm should have already received from the PIA application forms and guidance notes relating to individual registration of key staff, and these must be returned by the end of March 1998. Failure to meet this deadline may lead to the imposition of an administrative surcharge and disciplinary action by PIA.

The effect of individual registration will be to put in place a contract between significant individuals within an organisation and the PIA. This will give the PIA the right to take action against (in effect, to discipline or terminate the registration of) persons who do not comply with PIA's obligations.

One major change which was announced on 1 December 1997 is that not only principals (meaning sole traders, partners or directors), but managers (individuals with responsibility for managing regulated activities such as compliance officers, senior managers responsible for the conduct of the pension review, or managers responsible for advisers) and advisers (meaning representatives of a product provider, advisers at an IFA, pension funds specialists, and training and competence supervisors) must be registered. This widening of the net is expected to lead to around 100,000 applications for individual registration.

For most of these people, the "contract" between PIA and the registered individual will come into force on 1 October 1998. However, for the following organisations, PIA will to bring the contract into force on 18 May 1998:

  • Life offices;

  • Marketing associates;

  • Banks;

  • Directive friendly societies;

  • IFA networks; and

  • IFAs with 26 or more financial advisers.

This is largely to enable PIA to further hold to account senior managers of firms most involved with the pensions review.

The main checklist for PIA registered firms in relation to individual registration is therefore as follows:

  • ensure that you have received and understood the PIA's information pack;

  • appoint an individual within your organisation to be responsible for organising the submission of completed application forms;

  • consider who needs to be registered and allocate appropriate resources to the nominated individual to ensure that the registration process is completed on time; and

  • ensure that registered individuals are aware of their new responsibilities:
    -the Senior Executive Officer will carry ultimate responsibility for the management of a firm;
    -the Compliance Officer will need to ensure that a firm's systems and compliance culture can achieve satisfactory compliance with the regulator's requirements; and
    -each manager and adviser will have an individual contract with the PIA which will allow them to be directly disciplined if they do not follow their firm's procedures or the PIA's rules.