How do I decide which of my staff should be included within the requirement that 90% of customer-facing staff should be CII members?
Ideally the CII would require 100% of customer-facing staff to be members however the 90% rule is a practical guide on membership requirements. By requiring, as a minimum, only 90% of customer-facing staff to be members, firms are able to exclude staff whose customer-facing activities are peripheral to the firm’s business activities. It also provides a degree of protection in respect of natural fluctuations in staff numbers, which could otherwise lead to a contravention of the membership requirement. For guidance, all staff acting in an advisory capacity need to be members. Beyond this, any member of staff that has customer contact should be included, such as para-planners, account-handlers and personal assistants who regularly liaise with clients. Typically, however, this would not include accountancy personnel, receptionists or the like, though it remains at the firm’s discretion as to whether to include these positions.
