On March 20, the UK’s Financial Conduct Authority (FCA) and the UK’s Prudential Regulatory Authority (PRA) separately published guidance on steps for firms to take to identify key workers in the financial services industry (as, exceptionally during this crisis period while schools are closed, the children of such key workers may continue to attend UK schools).

The regulators acknowledge the exceptional circumstances caused by the COVID-19 pandemic but recognize the need for key workers in the financial services industry to continue work — specifically for the provision of essential financial services to consumers or to ensure the continued functioning of markets.

Both the FCA and PRA provide guidance to firms to help them identify their key financial workers, which includes:

• identifying the activities, services or operations that, if interrupted, are likely to lead to the disruption of essential services to the real economy or financial stability; and

• identifying the individuals who are essential to support those functions as well as any critical outsource partners who are essential to continued provision of services.

The regulators recommend that a firm’s SMF1 chief executive officer (CEO) (or equivalent member of the senior management team) should be accountable for ensuring that only roles meeting the definition are designated.

The types of roles that may be considered as providing essential services could be:

• in the firm’s overall management, such as individuals captured under the Senior Managers Regime;

• in the running of online services and processing;

• in the running of branches and providing essential customer services;

• to the functioning of payments processing and cash distribution services;

• in facilitating corporate and retail lending;

• in the processing of insurance claims and renewals; and

• in the operation of trading venues and other critical elements of market infrastructure.

The regulators ask firms to consider issuing a letter to all identified individuals, which can be presented to schools on request. They also suggest wording for the letter and that it should be signed by an appropriate person.

FCA guidance is available here and the PRA statement is available here.