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New starter vs annual fit and proper tests

How much difference is there between a new starter fit and proper assessment and an annual renewal for an existing employee?

Guidance from the FCA states that fitness and propriety assessments should cover the following:

· Honesty and integrity

· Reputation

· Competence and capability

· Financial soundness

This does not mean that every assessment should be the same, a specific difference is likely to be the way that your firm handles new starter assessments versus annual renewals.

In particular, when a new employee joins your firm into a certification role there will be external checks that you will need to undertake but you are unlikely to have any internal information to support that assessment.

When that same employee needs to have their certification renewed at the end of the year, you should have plenty of internal information that you have gathered about that employee. It is also likely that you will want to tie the individual’s annual certification into their appraisal process which will also generate assessment information.

In practical terms, you may want to consider some or all of the following sources of information for new starter or annual FIT assessments.

New starter

  • Regulatory references – this is mandatory

  • Character references or professional references from a line manager, colleagues or other relevant parties (e.g. where a person is joining from an unregulated sector)

  • Job application form

  • Interview notes

  • Other interview information (for example, from an assessment centre)

  • Professional or post graduate qualifications required for the role

  • Statement of Professional Standing (if available)

  • Undergraduate and other educational qualifications

  • Screening checks possibly including:

o Disclosure and barring (DBS)

o Company searches

o Sanctions check

o Professional body registers

o Credit reference agency

o County court judgment

o Bankruptcy order

  • Self-declarations to cover all four areas of the FIT assessment

Annual certification renewal

  • Performance appraisal – this could include:

o Annual performance evaluation

o 360 degree feedback

o Attendance at mandatory internal or external training and events

o Record of Continuous Professional Development (CPD)

o Performance improvement plan (if available)

  • Customer/client feedback

  • Professional connection website

  • Media profile

  • External publications

  • Self-declarations to cover all four areas of the FIT assessment

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