- Obtain an up-to-date job description.
- Note the nature of the fit and proper assessment (new role vs annual vs triggered vs in-year).
- Gather evidence for each fit and proper ‘pillar’, being
- Honesty, integrity and reputation,
- Competence and capability, and
- Financial soundness.
- Identify (and record) gaps in evidence.
- Confirm the extent to which evidence is verified.
- Identify Certification Risks and Certification Issues.
- Identify mitigating and aggravating factors.
- Identify mitigating and remedial steps.
- Issue certificate for those assessed as fit and proper.
- For those assessed as not fit and proper:
- Identify and communicate the steps (if any) the firm proposes to take as a result of the decision and the reasons for proposing to take those steps.
- Notify the FCA (Senior Managers)
- Prevent the individual from performing the relevant Certification Function(s) (Certification Employees)
