Controlled Function Confusion
Controlled Function Confusion
The introduction of the Markets in Financial Instruments Directive (MiFID) has brought confusion as individual controlled functions for approved persons merged into one.
Before MiFID’s introduction, there were seven different controlled functions for approved persons. These were CF21 to CF27. Now there is one – CF30, called the Customer Function (strange use of terminology as we thought customers were now clients…)
You can see the full list of controlled functions on the FSA website but you will need to ‘time travel’ the hand book to 31 October 2007 to see the names and definitions of the old controlled functions CF21 to CF27.
Whilst the customer functions are now merged into one, the FSA expects nothing to change in terms of the experience and qualifications needed for an approved person to carry out the duties under CF30 than they did under the individual functions CF21 to CF27.
The merging of the controlled functions places more emphasis on you as a firm to ensure everyone undertaking the various duties within CF30 is experienced and qualified to do so.
Our recommendation is to keep a list of the old controlled functions and which of your approved persons they are relevant for. Whilst they will show officially as CF30, their supervision and T&C programme should not change.
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