Reference Case Number: FOI11696
Freedom of Information: Right to know request:
Please provide information pertaining to the average tenure of individuals in designated roles.
FCA response:
1. Over the last five years (2024 included) what is the average tenure of individuals in the designated roles below? a) CASS oversight (SYSC 27.8.1R) b) Proprietary trader (SYSC27.8.3R) c) Material risk-takers (SYSC 27.8.14R) d) Client-dealing (SYSC 27.8.18R)
For this part of the request, we have calculated the average tenure of individuals in each of the four requested roles:
| CASS Oversight | 944 days |
| Proprietary Trader | 817 days |
| Material Risk Taker | 752 days |
| Client Dealing | 877 days |
The average has been calculated based on the provided start and end dates of the individual’s time in the role, from directory persons data provided by firms. If the individual was still in a role at the date of extract (08/10/24), then the date of extract was used as the end date for the purposes of calculating average tenure. If the start and end date of the involvement were the same day, we counted this as 1 day.
2. The answer to 1 broken down by firm type e.g. asset manager, wealth manager, broker, etc.
The average tenure in days for each of the roles, using the same methodology as in question 1, has been provided broken down by the primary portfolio of the associated firm. The data can be found in Annex A below.
Caveats and Clarifications:
- It may not be possible to ascertain the actual tenure of individuals in these roles. This is because the start dates reflect when these roles became subject to the certification regime. This started for some firms in 2016 and expanded to all firms in December 2019. It will not reflect tenure in the role before they became in scope of the certification regime. Solo-regulated firms were not required to submit Directory persons data until 31 March 2021.
- If the status end date was a future date, the extract date of 08/10/2024 was used for these entries to calculate tenure up until the date of extraction.
- Directory persons data is provided by firms. The firms are responsible for supplying us with accurate information. We cannot guarantee its accuracy, and it may contain errors or missing information.
- The primary portfolio of a firm reflects the current portfolio that a firm is in (or the most recent portfolio of the firm for firms that are no longer authorised).
- Some firms have no primary portfolio assigned and so are excluded from this breakdown. This would occur, for example, if the firm’s permissions were cancelled before the firm was assigned to a portfolio.
- Some portfolios have a very small number of firms currently assigned to them. This may occur where a portfolio is, for example, no longer used, and the firms are being reassigned to other portfolios. To note, Wholesale (Other) is a portfolio which has largely ceased to operate which contained heterogenous business models and have now been allocated to other existing portfolios.
Annex A
CASS oversight Function
| Portfolio | Average Tenure |
|---|---|
| Advisers and Intermediaries | 997 |
| Alternatives | 1005 |
| Asset Management | 884 |
| Claims Management | 1408 |
| Contracts for Differences (CFD) Providers | 834 |
| Corporate Finance Firms | 1095 |
| Credit Brokers | 655 |
| Credit Unions | 762 |
| Crowdfunders (Investment) | 786 |
| Custody and Fund Services | 651 |
| Debt Advice Firms | 1074 |
| Debt purchasers, debt collectors and debt administrators | 1035 |
| High Cost Lenders | 1343 |
| Life Insurance | 712 |
| Lifetime Mortgage Providers | 456 |
| Lloyd`s and London Market Intermediaries (inc Managing General Agents) | 846 |
| Lloyd`s Managing Agents and London Market (Re) Insurers (inc P & I Clubs) | 754 |
| Mainstream Consumer Credit Lenders | 1670 |
| Mortgage Intermediaries | 1102 |
| Motor Finance Providers | 1397 |
| Multilateral Trading Facilities and Organised Trading Facilities | 456 |
| Non-Bank Lenders | 950 |
| Peer-to-Peer lending platforms | 1187 |
| Personal and Commercial Lines Insurance Intermediaries | 1054 |
| Platforms | 785 |
| Principal Trading Firms | 1191 |
| Retail Bank | 675 |
| Retail Finance Providers | 818 |
| SIPP Operators | 661 |
| Wealth Management | 915 |
| Wholesale (Other)[PW1] [JT2] [PW3] | 770 |
| Wholesale Bank | 643 |
| Wholesale Brokers | 664 |
Proprietary trader
| Portfolio | Average Tenure |
|---|---|
| Advisers and Intermediaries | 927 |
| Alternatives | 904 |
| Asset Management | 752 |
| Building Societies | 646 |
| Claims Management Companies | 1464 |
| Contracts for Differences (CFD) Providers | 988 |
| Corporate Finance Firms | 842 |
| Credit Brokers | 1013 |
| Credit Unions | 1677 |
| Custody and Fund Services | 791 |
| Debt Advice Firms | 1420 |
| High Cost Lenders | 1313 |
| Life Insurance | 303 |
| Mortgage Intermediaries | 1218 |
| Motor Finance Providers | 1689 |
| Non-Bank Lenders | 1300 |
| Personal and Commercial Lines Insurance Intermediaries | 1132 |
| Principal Trading Firms | 808 |
| Retail Banks | 547 |
| Retail Finance Providers | 1549 |
| Wealth Management | 704 |
| Wholesale Banks | 621 |
| Wholesale Brokers | 1027 |
Material risk taker
| Portfolio | Average Tenure |
|---|---|
| Advisers and Intermediaries | 932 |
| Alternatives | 872 |
| Asset Management | 805 |
| Benchmarks | 695 |
| Building Societies | 635 |
| Claims Management Companies | 1596 |
| Contracts for Differences (CFD) Providers | 841 |
| Corporate Finance Firms | 835 |
| Credit Brokers | 720 |
| Credit Unions | 837 |
| Crowdfunders (Investment) | 724 |
| Custody and Fund Services | 642 |
| Debt Advice Firms | 578 |
| Debt purchasers, debt collectors and debt administrators | 718 |
| Exchanges | 674 |
| High Cost Lenders | 1486 |
| Life Insurance | 576 |
| Lifetime Mortgage Providers | 295 |
| Lloyd`s and London Market Intermediaries (inc Managing General Agents) | 1074 |
| Lloyd`s Managing Agents and London Market (Re) Insurers (inc P & I Clubs) | 807 |
| Mainstream Consumer Credit Lenders | 554 |
| Mortgage Intermediaries | 1185 |
| Motor Finance Providers | 642 |
| Multilateral Trading Facilities and Organised Trading Facilities | 761 |
| Non-Bank Lenders | 576 |
| Payment services firms | 474 |
| Peer-to-Peer lending platforms | 1033 |
| Personal and Commercial Lines Insurance Intermediaries | 948 |
| Personal and Commercial Lines Insurers (inc EEA Insurers) | 626 |
| Platforms | 556 |
| Price Comparison websites[JT1] | 13 |
| Principal Trading Firms | 620 |
| Retail Banks | 627 |
| Retail Finance Providers | 693 |
| Retail Mortgage Lenders | 240 |
| SIPP Operators | 820 |
| Wealth Management | 944 |
| Wholesale (Other) | 541 |
| Wholesale Banks | 687 |
| Wholesale Brokers | 678 |
Client dealing
| Portfolio | Average Tenure |
|---|---|
| Advisers and Intermediaries | 1030 |
| Alternatives | 901 |
| Asset Management | 983 |
| Building Societies | 762 |
| Claims Management Companies | 1146 |
| Contracts for Differences (CFD) Providers | 825 |
| Corporate Finance Firms | 887 |
| Credit Brokers | 886 |
| Credit Unions | 1198 |
| Crowdfunders (Investment) | 900 |
| Custody and Fund Services | 719 |
| Debt Advice Firms | 1272 |
| Debt purchasers, debt collectors and debt administrators | 1218 |
| Funeral Plans (Providers and Intermediaries) | 304 |
| High Cost Lenders | 1383 |
| Life Insurance | 640 |
| Lifetime Mortgage Providers | 1162 |
| Lloyd`s and London Market Intermediaries (inc Managing General Agents) | 1075 |
| Lloyd`s Managing Agents and London Market (Re) Insurers (inc P & I Clubs) | 674 |
| Mainstream Consumer Credit Lenders | 843 |
| Mortgage Intermediaries | 841 |
| Mortgage Third Party Administrators | 787 |
| Motor Finance Providers | 998 |
| Multilateral Trading Facilities and Organised Trading Facilities | 825 |
| Non-Bank Lenders | 760 |
| Payment services firms | 1064 |
| Peer-to-Peer lending platforms | 1166 |
| Personal and Commercial Lines Insurance Intermediaries | 1097 |
| Personal and Commercial Lines Insurers (inc EEA Insurers) | 1529 |
| Platforms | 892 |
| Principal Trading Firms | 875 |
| Retail Banks | 608 |
| Retail Finance Providers | 1566 |
| SIPP Operators | 889 |
| Wealth Management | 1002 |
| Wholesale (Other) | 626 |
| Wholesale Banks | 666 |
| Wholesale Brokers | 832 |