It might possibly appear run-of-the-mill, to compare making an application for authorisation to a magic trick, However if you are under any impression that less-than-perfect preparation is good enough, take heed.
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.”
Needless to say, it’s hard to understand what others consider vexatious. Perhaps anything from slightly troublesome to thoroughly annoying or extremely infuriating. If indeed there’s a scale at all!
Fortunately, the FCA has certainly presented us a few clues.
When determining an application, your case officer is ultimately taking into account three things.
Before anything else, they try to find indicators of what you’ve undertaken when preparing your application. So they like to know things like whether or not you’ve read the facts on the FCA website, made enquiries of the contact centre, or pursued legal or professional compliance advice. They also evaluate your application on how clearly you’re able to articulate your regulatory obligations.
Second, they regard your attitude during the application process. (I’m sure they didn’t mean that to sound quite the way it does). They judge whether you’re being open and completely honest with them and proactive about obtaining details for them. They also wish to see that you are aware of your regulatory obligations and react promptly to any questions they have about your application.
Third, they really want to be sure you have your supporting documentation prepared and arrangements readily available to comply from the first day you become authorised. So they take into consideration why you’re applying now, what’s still outstanding that would prevent you from doing whatever you’ve applied for, and whether you would have the capacity to do that activity if you were authorised immediately.
You need to successfully pass all three of these ‘tests’. It’s insufficient, for example, being happy to correct mistakes or gaps in your application if you fell over 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 all throughout the process, they want to be sure you’re ready, willing and organised to adhere to the rules and requirements at all times.
Lee Werrell Chartered FCSI FISM
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