The vast majority of financial adviser firms employ staff who will be affected by these requirements.
Only by constructing, or reviewing, job descriptions carefully against each ESMA competency will it become clear if staff are performing a role to which any of these competencies will apply. This may involve changing staff roles and/or job descriptions to deliberately include or exclude certain members of staff as appropriate
Once firms have drawn up a list of non-advising staff who fall under the ESMA guidelines, firms will then need to evidence their competence. To help our clients tackle this, we use a shortened training and competence plan specifically for non-advising staff, setting out KPIs and a programme of CPD material.