The BSA's key comments are as follows:

• We support the proposal to include all senior managers in a public register although we believe that, ideally, the FCA should simply extend the Financial Services Register for this purpose. If that is legally problematic or impracticable, we support the proposal for a Directory insofar as it comprises information on senior managers.
• However, we see no benefit, and considerable potential disadvantages, in including non customer-facing certification staff (especially back office functions) within the Directory and, therefore, do not support that element of the proposals.
• We understand the reasoning behind the proposal to include certificated customer-facing staff in the Directory, but would support the proposal only if there were robust assurances regarding certain concerns - especially fraud risk and data protection issues.
• Finally, we believe that the proposed requirement for reporting changes are too stringent and inconsistent with requirements relating to parallel arrangements. We respectfully urge the FCA to modify them.

Therefore, in our view the FCA should –

1. drop the proposal to include non-customer facing certification staff in the Directory,
2. carefully reconsider the potential adverse consequences of including customer facing certification staff, ensuring proper safeguards if that element of the proposals goes ahead, and
3. in line with ii above, ensure appropriate safeguards regarding senior managers’ personal information included in, or accessible through, the Directory, and
4. bring the proposed reporting requirements in line with normal practice.

Read the full response here.