FCA Authorisation Applications Are Receiving Greater Scrutiny
It may appear run-of-the-mill, to compare submitting an authorisation to a magic trick, However if you’re under any false impression that less-than-perfect preparation is good enough, beware. Sarah Rapson, Director of authorisations at the FCA said that, “We have begun to take a harder line on submissions that border on the vexatious.”
Obviously, it’s hard to identify what others consider to be vexatious. Perhaps its just about anything from slightly frustrating to thoroughly annoying or absolutely infuriating. If indeed there’s a scale at all!
The good news is, the FCA has already presented us a number of clues.
When reviewing an application, your case officer is primarily taking into consideration three things.
To start with, they seek out signs of what you’ve accomplished when preparing your application. So they like to know details like whether you’ve read the facts on the FCA website, made enquiries of the contact centre, or secured legal or professional compliance advice. They also determine your application on how clearly you’re able to articulate your regulatory obligations.
Secondly, they regard your attitude during the application process. (I’m sure they didn’t mean that to sound quite the way it does). They evaluate whether you’re being open and completely honest with them and practical about obtaining details for them. They also want to see that you comprehend your regulatory obligations and react promptly to any questions they have about your application.
Finally, they want to make sure you have your supporting documentation well prepared and arrangements readily available to comply from the first day you become authorised. So they keep in mind why you’re applying now, what’s still outstanding that would stop you from doing whatever you’ve made an application for, and whether you would have the ability to do that activity if you were authorised right away.
You need to pass all three of these ‘tests’. It’s not enough, for instance, to be about to correct mistakes or gaps in your application if you fell at the first hurdle. Quite clearly, they ‘d find this vexing!
“We will move to refuse firms earlier on in the authorisation process where the firm is not ‘ready, willing and organised’ to operate in the regulated financial services market,” Rapson has said.
And those are the magic words: ready, willing and organised. From the day they receive your application, and during the course of the process, they want to make certain you’re ready, willing and organised to adhere to the rules and requirements at all times.
This is why Compliance Consultant have revised their application processes and include time onsite with you to work through any areas of potential issue and enhance your understanding.