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10 Practical tips for a smooth FCA application process

28 June 2017

The road to FCA authorisation can sometimes seem a long one, but take in some of our top tips for FinTechs travelling this road for the first time to help smooth the ride.

1. Do some prior research

It is advisable to familiarise yourself with the contents of the application forms, and the requirements for authorisation for your type of firm, so that you can quickly identify any gaps in your firm's overall framework.

 

2. Dedicate time to completing the forms

There are a number of lengthy forms to complete and it is important to set time aside in your diary in order to make the process more manageable around your daily business.

 

3. Sensitive business names

Legislation provides a list of business names that are classified as 'sensitive'. These are names that can give a misleading impression of what the business does, for example, insurance, underwriting, fund, and so on.

The FCA advises that if your firm is not yet authorised, you should register a different name with Companies House, and then apply to change it once authorisation has been granted.

For more information please see the FCA page on sensitive business names


4. Understand what is applicable to your firm

A large number of firms apply to vary their permissions within the first year of authorisation, which incurs additional application costs, and can impact your firm's ability to fully offer its proposed range of services or products. Ensure you select all the relevant permissions according to the business model you have outlined.

 

5. Ensure you submit a complete application

Incomplete applications are the main cause of delays, so it is important to ensure all questions on the relevant forms are answered, and any requested additional documents are provided to avoid your application being deemed incomplete.

 

6. Demonstrate readiness

The FCA wants to see that firms are 'ready, willing, and organised' to trade and comply with regulatory requirements once authorisation is granted. Ensure that this is demonstrated throughout your application in the answers and documents you provide. To this end, it is advisable to have tested IT systems, and have prepared internal policy documents that show your firm will not fall foul of regulatory requirements from the gate.

 

7. Disclosure

Be up front with the FCA and provide detailed information about any adverse events that may impact your application. The application forms point out what the FCA would be interested to know about. Non-disclosure is more likely to result in delays and to cause a negative opinion about your firm to be formed by the regulator.

 

8. Expect to answer further questions

As part of the assessment process, the FCA will ask follow up questions, and may ask for additional documents and evidence. Provide detailed answers in a timely manner, and avoid pushing back and coming across as resistant, as this could cause undue delay.

 

9. Be detailed but keep it precise

Simply put, if it isn't relevant to the question, there's no need to mention it. Irrelevant information can add to the time it takes to process your application.

 

10. Be patient

Unfortunately there is no way of securing a guarantee of when your application will be determined. Guidelines around timescales are quite loose. The FCA has 6 months from the date of submission to determine an application deemed complete, and 12 months for an incomplete application. It can also take some time for your application to be allocated to someone for review, so be prepared to sit tight.

 

Find out more about how we can support your FCA application process with our new Authorisation Tool. It will easily guide you through the key stages of the FCA’s authorisation process, providing a tailored, fixed-fee package of support for your application journey. The Authorisation Tool can be found on our new LawTech solution Hogan Lovells Engage.

Mary Ogunniya

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