unrestricted getting fca authorised 1. unrestricted our approach 2 fca approach gateway is key high...
TRANSCRIPT
Unrestricted
1
Unrestricted
Getting FCA authorised
Unrestricted
2
Our approach
FCA approach
Gateway is key
High minimum standards
Getting inside your business
Flexible for different size firms
Unrestricted
3
The journey for your firm
OFT regulation
FCA interim permission
FCA application
FCA authorisation
Unrestricted
4
Step 1
Now• If firms want to
start offering consumer credit
Your application
period
• If firms have interim permission
• If firms miss this date, they will need to stop regulated credit activities
When to apply
Unrestricted
5
The difference between a permission and the consumer credit licence (CCL)• There’s no longer a licence, and no longer categories A,
B, C etc
• The authorisation application is a fresh start and is unrelated to the CCL
• Firms apply for ‘Part 4A permission’: and have to choose full or limited permission
• Firms choice is based on the regulated activities they carry out (i.e. the type of business) :– Some activities mean firms have to choose ‘full permission’ – Some activities will allow firms to qualify for ‘limited permission’
Unrestricted
6
Step 2: Decide the level of permission
Two categories of FCA permission
Full permission
Limited permission
Unrestricted
7
How to decide the permission level
1• Look at what credit business
the firm does
2• See how it matches FCA
‘regulated activities’
3• Check whether those activities
mean full or limited permission
Unrestricted
8
Step 3: Prepare the application
• Firms will need to give us detailed information about their business
• Firms may need to prepare their supporting information now even if they plan to apply in several months’ time
• Firms should review our website to see what we will ask them to include, then start collating the information now
Unrestricted
9
Examples of what we will ask for
• Basic information about the firm• How the firm is set up, who works there• Who owns or influences the business
(controllers)• How firms make their money (business plan)• How firms make sure their business keeps to
our rules (compliance monitoring)• Financial information• The firm’s history and any ‘significant
events’ we should know about
Unrestricted
10
Approved persons
• Our approach is to ensure senior management responsibility
• Having ‘approved persons’ is a key way to achieve this
• Senior individuals in the firm will need to apply to be the approved person, and prove they are fit and proper
• We will hold the person accountable
Unrestricted
11
Step 4: Apply
• Most firms apply using our Connect online system
• We have help text within Connect and guidance forms you can download on our website
• You may need to send in a paper form if you are already regulated by us for other things
Unrestricted
12
How much it costs to apply
• Firms will need to pay an application fee when they apply
• The fee will be a calculation based on how complex we think the application is and the consumer credit income
• We have put all firms into different complexity categories based on what they do:– Limited permission– Straightforward: eg credit broker– Moderately complex: eg, lender– Complex: eg debt management company
Firm’s credit income
Limited permission
Straight-forward
Moderatelycomplex
Complex
Up to £50,000 £100 £600 £800 £1,000
£50-£100,000 £500 £750 £1,000 £1,250
£100-£250,000 £500 £1,000 £1,500 £2,000
£250,000-£1 m £500 £1,500 £5,000 £7,000
over £1 million £500 £5,000 £10,000 £15,000
Application fee breakdown
13
Unrestricted
14
Firms details should be kept up to date through our consumer credit interim permission website: search “CCI” on fca.org.uk
Changing firm’s details during interim permission
Unrestricted
15
• All authorised firms will appear on our register• Our enforcement team will seek out firms that
carry on credit business without permission
Ensuring a level-playing field