As you’ll know, one of the outputs of PS09/14 was that the scope and application of CF1 (director function) and CF2 (non-executive director function) was extended to capture individuals such as directors employed by a holding company whose opinions and actions are regularly taken into account by the governing body of the authorised firm.
Sup 10.6.5G provides us with examples of such individuals who may require to be approved for the CF1 function. However SUP 10.6.4G specifically excludes LLPs. They have not carried the principle over to the CF4 (partner function).
Therefore if the authorised firm is an LLP they will not be affected by these changes. Having spoken to the FSA this appears to be down to the drafting rather than being intentional. We are advised that the FSA are looking at the issue.
Interestingly, the rule in respect of the CF2 function doesn’t exclude LLPs.