FCA authorisation can be delayed by errors in the application process that could have been avoided with prior knowledge of where firms commonly go wrong.
Vague Regulatory Business Plan
Description of the regulated activities that the applicant will carry out, for whom and how, within a Vague Regulatory Business Plan.
Missing Financial Projections
3 years of financial projections (as detailed as possible and including a balance sheet, profit & loss account and cash flow) and the basis on which they were arrived at. Assumptions not supported by evidence are likely to be expected.
Weak Compliance Arrangements
Document your compliance monitoring program, your appointed Compliance Officer and your complaints process. The FCA will assess your application against what it expects at each stage of the application process and therefore expects you to have written procedures in place. See also www.adempi.co.uk/fca-authorisation.
Unsuitable Approved Persons
As for the Approved Persons for each of the Controlled Functions, the following is expected: each must supply a current CV together with a completed Form A and relevant supporting evidence (such as past employment contracts or other documents) which establishes their relevant experience.
Poor Client Categorisation
You must describe the type of client (retail, professional etc) that you will be serving and describe how you will categorise clients within your organisation. A common mistake is to leave this section undefined leading to FCA requisitions.
For practical support preparing your submission, Adempi covers the full authorisation process.
Getting the detail right the first time is the simplest way to avoid a lengthy back-and-forth with the regulator.
