FCA warns of hybrid working practices

The regulator explains that firms considering remote or hybrid working will be evaluated by the regulator on a case-by-case basis.

Financial sector firms should be able to prove that the lack of a centralised location or remote working does nor is unlikely to:

• Affect the firm’s location in the UK, or its ability to meet and continue to meet the threshold conditions for the regulated activities it has or will have permission for – or any equivalent requirements, where these do not apply.
• Prevent the FCA receiving information about a firm.
• Reduce the accuracy of the Financial Services (FS) Register for others if, for example, consumers are not able to contact the firm at the principal place of business shown on the FS Register. 
• Affect the ability of the firm to oversee its functions including any outsourced functions

Additionally firms must be able prove that there is “satisfactory planning:

• That there is a plan in place, which has been reviewed before making any temporary arrangements permanent and is reviewed periodically to identify new risks.
• There is appropriate governance and oversight by senior managers under the Senior Managers regime, and committees such as the Board, and by non-executive directors where applicable, and this governance is capable of being maintained. 
• A firm can cascade policies and procedures to reduce any potential for financial crime arising from its working arrangements. 
• An appropriate culture can be put in place and maintained in a remote working environment. 
• Control functions such as risk, compliance and internal audit can carry out their functions unaffected, such as when listening to client calls or reviewing files. 
• ..and more.

The FCA adds that firms should consider if their details on the FS Register need updating.