the nature, scale and complexity of its business, the nature and range of financial services and activities undertaken in the course of that business; and
The criteria listed in FIT 2.1 to FIT 2.3 are guidance and will be applied in general terms when the FCA 1 is determining a person's fitness and propriety. It would be impossible to produce a definitive list of all the matters which would be relevant to a particular determination. An SMCR firm2 assessing the fitness and propriety of staff being assessed under FIT should be guided by substantially the same criteria in FIT 2.1 to FIT 2.3 (to the extent applicable to the firm), recognising that this is not intended to be a definitive list of matters to be considered. 11
If a matter comes to the FCA's 1 attention which suggests that the person might not be fit and proper, the FCA 1 will take into account how relevant and how important it is. In the same way, if a matter comes to the attention of an SMCR firm2 which suggests that any staff being assessed under FIT might not be fit and proper, the firm should take into account how relevant and how important that matter is. 111
1An SMCR firm2 assessing the continuing fitness and propriety of an approved person is required to notify the FCA under section 63(2A) of the Act if it forms the opinion that there are grounds on which the FCA could withdraw its approval (see SUP 10C.14.24R). In discharging its obligation to notify the FCA, an SMCR firm2 should take into account how relevant and how important the matter is that comes to its attention which suggests an approved person might not be fit and proper before determining that a notification should be made.
1An SMCR firm2 assessing the continuing fitness and propriety of staff being assessed under FIT should assess the role that the individual is actually performing at the time the assessment is done. For this purpose, the assessor(s) should be provided with an up-to-date job description for that individual in advance of the assessment.