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At Better Way FX Consulting we have the ability to give you as our client a holistic view of your options and we create a road map that will accelerate your business set up and support expansion and revenue growth.
The FCA state that they process most applications well within the statutory standards as set out in the Financial Services and Markets Act, which allow them 6 months to process a complete application and up to 12 months from receipt of an incomplete application (i.e. if information or documents required to be submitted as part of the application pack are not provided).
Just for reference, before the FCA was appointed, the FSA stated that a straightforward application deemed as complete, used to take between two and three months from submission to authorisation (as published on the Service Standards – Authorisation page).
The FCA, as the new regulator, said they intend to revise the authorisation service standards, which were meant to be published in April 2014. From our experience with applications submitted to the FCA over the past 12 months (since the FCA’s inception) for different types of firms and authorisations, the timeline for processing an application pack seems to have extended compared to what used to happen with the FSA. In particular, many applications have been delayed considerably due to the long time it took the FCA to allocate the application pack to a case officer (as long as six months from date of submission!), even before they could assess the complexity of the application or whether it could be deemed as complete.
Most rigorous elements of the procedure:
- Application pack to be submitted as complete: the FCA expect the applicant firm to complete the appropriate application forms with all the information required and provide comprehensive supplementary information including a detailed business plan, financial projections and a compliance monitoring programme. In the course of the review process the FCA’s case officer is likely to ask questions and request additional information even if the application was deemed to be complete when submitted;
- Individuals: the individuals who seek to cover controlled functions and in particular those responsible for the management of the applicant firm, must demonstrate their fitness and propriety (ie. no criminal records or disciplinary measures) as well as knowledge and experience of the financial sector in the UK (ie. knowledge of the regulatory framework and sufficient experience to be able to run the firm effectively). In order to assess the suitability of individuals, the FCA may request additional personal information as well as arrange face to face interviews with the candidates;
- Governance: the corporate governance arrangements within the applicant firm must meet very high standards, to demonstrate that the firm is appropriately organised to be run effectively. Focus will be placed on apportionment of roles and responsibilities, allocation of management functions, clear reporting lines, staff organisation structure, systems and controls to ensure the firm can be run in compliance with applicable rules and regulations, how it will satisfy the threshold conditions at all times and how it will be able to prevent financial crime, money laundering, market abuse or bribery in the course of its activities;
- Ownership: the applicant must provide detailed information on any controllers and ultimate beneficial owners including any associated entities or individuals deemed to be close links who might affect the firm’s business;
- IT systems: for certain types of firms, including those using dealing platforms or relying substantially on software and telecommunication solutions, the firm may be required to provide a very detailed assessment of the soundness and effectiveness of the IT systems used, to the extent of requiring a full IT systems audit by specialised professionals;
- financial resources: an applicant firm will be subject to specific capital requirements from the day it is authorised and the FCA will request evidence, before they grant authorisation, that the appropriate amount and quality of financial resources have been injected in the firm to ensure capital adequacy.
In summary the application process is not straightforward and applicant firms must be able to demonstrate that they are ‘willing and ready’ to become authorised, which means they must be prepared to invest time and resources into the application process which can only be made less onerous with the assistance of specialised consultants.
FCA regulated entity
- Set up plan
- We assist your company with a comprehensive plan describing all the components needed to start an FCA licensed operation from every angle. We provide tools according to predefined parameters agreeable with the client that enable better and wiser, and more cost effective decisions
- We work closely with industry experts specialized on FCA regulation, procedures and recruitment that will help your brokerage set up the UK operation in the most efficient and adaptable way to your business needs and strategy. Many brokers have different goals when exploring the chance of setting up an FCA regulated entity, therefore Better Way experts cater different possibilities to cope with the client’s objectives.
- Office set up
- We work with leading and open minded commercial property experts in London that will help us find the best office space for your company in terms of location, cost, potential growth, facilities and availability.
- We aim to build long-term relationships with clients and candidates providing help, support and guidance throughout the search process for both parties. We collaborate with clients to pre-empt and optimise the execution of searches, applying professional analysis of markets, competitors, key trends and news flow together with using our partners and third party relationships to support day-to-day operations.
- Professional Services
- Accounting and Reporting: we understand that working in the financial service environment creates a number of challenges. Through carefully selected industry partners we can help you with bookkeeping services, financial statements preparation but can also focus on particular areas of your accounts, such as Taxes or bank reconciliations. We will agree the most appropriate and efficient way to exchange information.
- Applying professional analysis of markets, competitors reaction to new entries, key market trends and news flow together with using our networks will provide you with easy to understand reports and commentary that could help save you energy, money and help you make better and wiser decisions.
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