2021 New PCFs Proposal

CBI Proposed Changes to PCF’s – What Action will be Required

The Central Bank has published a ‘Notice of Intention’ to amend the list of PCF roles. With one exception (removal of PCF-31, Head of Investment) the amendments will apply to all Regulated Financial Service Providers (RFSPs).

Consultation ends on 21 October and once the new Regulations are issued, RFSPs will have six weeks to register the necessary changes, including the due diligence refresh.

Transition action for in-situ individuals will be required as follows:

1. Expansion of PCF-16 to non-EEA branches

In-situ managers of branches outside the EEA (incl. UK) will have to be assessed against the F&P standards and such assessment notified to the CBI. Note that a PCF application to CBI will not be required for in-situ branch managers.

2. Segregation of PCF-2 into PCF-2A (non-executive director) and PCF-2B (Independent Non-Executive Director

All PCF-2’s will be re-designated by CBI as PCF-2A. RFSPs must notify the CBI of those PCF-2’s which are deemed to be Independent (PCF-2B) and must confirm that they have undertaken the relevant due diligence to assess independence.

3. Split of PCF-15 into PCF-12 (Head of Compliance) and PCF-52 (Head of Anti-Money Laundering and Counter Terrorist Financing

Current PCF-15’s will be end dated on the CBI register and RFSPs must notify the CBI of the appropriate designation for the in-situ individual (PCF-12, PCF-52 or both).

Where it is deemed that the RFSP has an in-situ person carrying out the function of PCF-52, who is not currently the PCF-15 designated person, the person should be assessed against the standards and notified to the CBI.

4. Removal of PCF-31

No action required – all existing holders will be automatically re-designated as PCF-30 (Chief Investment Officer)