[Emma]

Hi all,

We have a ‘sister’ charity with a remit for financial inclusion, which is currently run entirely by CU staff and volunteers. We’re looking to directly employ some staff via the charity for the first time, and I am trying to get my head around which, if any, regulatory requirements for CU staff will also apply to employees of the charity.

Charity employees won’t be handling member accounts, taking payments, or engaging in any deposit-taking or lending activity; but they will be representing and generally promoting SCU, so we need to make sure our oversight is appropriate.

I think I’ve confirmed that they will not be subject to the Conduct Rules, we’ll be fine on bribery, and I’ll address financial promotions regs as and when; but I’m less certain about AML and Consumer Duty requirements. They will be working very limited hours so I’m trying to keep the training schedule as slim as is reasonably possible.

If anyone has experience of an arrangement like this, I’d be grateful to hear how you’ve handled it, and whether there are any pratfalls!

Emma K Carpenter - Compliance Officer - Sheffield Credit Union

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