To rephrase the Bard, this should not really be the question – there is a better option.
Representatives appointed in the second half of 2013, and the first half of 2014, and who are required to successfully complete the RE 5 by the 30 June 2016, need not be debarred. Such persons can simply be removed from the rep register before the end of June 2016.
They will then not be allowed to provide financial advice or intermediary services, but can be employed in other capacities while they study and write again as soon as possible.
The following table, provided by the FSB, clearly sets out who is obliged to comply by today.
| Representatives’ DOFA | RE 5 Deadline |
| 30/06/2013 – 31/12/2013 | 30/06/2016 |
| 01/01/2014 – 29/06/2014 | 30/06/2016 |
| 30/06/2014 – 31/12/2014 | 30/06/2017 |
Employers who fail to remove a representative from both the FSP’s and the FSB’s central rep register prior to the due date to satisfy a particular Fit & Proper requirement are legally obliged to debar them on 1 July 2016.
