Skip to main content

IM&W - Authorisation as a regulated firm

Supporting both new market entrants with the UK regulatory authorisation application process, and existing firms with Change in Control (CiC) applications and Variation Of Permissions (VOP).

Regulatory Expectations

Firms that want to undertake regulated activities in the UK must be authorised by the FCA and, depending on the activities being undertaken, they may also require authorisation by the PRA. Without a clear plan, obtaining authorisation can be a challenging process. We are able to support firms with their journey to becoming authorised, including meeting the extensive set of requirements set by the regulator and preparing the documentation that needs to be submitted. It is important that firms demonstrate, through the authorisation process, that their internal processes support their ability to meet the relevant threshold conditions and that the granting of permission(s) will not harm the achievement of regulatory objectives.

A similar process applies to existing firms looking to undertake a VOP to either change or add to its regulatory activities, or a CiC process following a change of ownership and / or Mergers and Acquisitions (M&A) activity.

Timeline: 


Regulators expect firms to be “Ready, Willing and Organised” in order to demonstrate their ability to comply with their applicable rules and guidance. A typical application follows a number of key stages with several documents expected to be prepared in advance. The typical timing from start to finish is on average about 12-18 months depending on complexity:

*The statutory timeline to review a complete application is 6 months under FSMA, but regulators note that the process can take up to 12 months for applications that are incomplete. Timeline provided based on an example of an IM&W firm.

Our capabilities:

Our Authorisations Team have deep expertise and a proven track record of helping manage the authorisation process to a successful completion. Together with Deloitte’s extensive network of SMEs and drawing on a team including ex-regulators and industry practitioners, we can support you throughout the end-to end application process, including navigating any nuances and potential pitfalls you may face when seeking approval from the regulator.
 

Core risk and regulatory support:

Timeline

Regulators expect firms to be “Ready, Willing and Organised” in order to demonstrate their ability to comply with the applicable rules and guidance. A typical application follows a number of key stages with several documents expected to be prepared in advance. The typical timing for a firm’s journey to authorization is on average about 12-18 months from start to finish depending on complexity.

*The statutory timeline to review a complete application is 6 months under FSMA, but regulators note that the process can take up to 12 months for applications that the FCA deems incomplete. Timeline provided based on an example of an IM&W firm.

Our capabilities

Our Authorisations Team have deep expertise and a proven track record of helping firms with the authorisation process, through to a successful completion. Together with Deloitte’s extensive network of SMEs and drawing on a team including ex-regulators and industry practitioners, we can support firms with the application process, including navigating any nuances and potential pitfalls faced when seeking approval from the regulator. Whether you need comprehensive, end-to-end support or assistance with a specific aspect of your application, we can tailor our support to your needs.

We can support firms with an up-front assessment of the feasibility of their business case pre-application. This includes support with any required regulatory permissions analysis, indicative regulatory requirement impact assessments, cost / benefit analysis and legal entity structuring.

We can help to navigate the strategic choices around business capabilities, whilst helping to think about how the strategic vision can be effectively considered. We can also help to establish a road map for delivery, including the use of technology to make this more efficient.

Through our extensive experience in successful end-to-end authorisations, we can leverage our SMEs to help organisations complete the application forms in line with expected best practice.

This is one of the most critical documents in an application. Utilising our wide range of SMEs, we can provide market-leading support with the development of RBPs in order to highlight the robustness of the proposed business model.

3–5-year forecasts are expected as part of any application and we can help to develop and document structured projections in line with the business model and the FCA’s expectations in this area.

Capital, liquidity and other prudential requirements can be complex, and we can support with assessing applicable requirements. We can also support with the development of important processes and documents such as the Internal Capital Adequacy and Risk Assessment (ICARA) document and Wind-Down Plan (WDP) document, which are key to demonstrating that the firm can meet threshold requirements.

Firms should have a suitable Risk Management Framework (RMF) in place to appropriately manage their risks. This should be in development ahead of submission to the regulator and we can provide support in RMF development.

We can help with the development of compliance monitoring programmes with a focus on outcomes and on the integration of key topics such as Consumer Duty and Assessment of Value.

Governance frameworks are expected to be in place with appropriate controls, oversight and culture to manage risk-taking ahead of authorisation. We can support with the development of appropriate governance structures to ensure that the regulator’s expectations are met. 

We can support with the analysis of regulatory reporting requirements and with assessing whether appropriate mechanisms / systems are in place to manage reporting obligations before authorisation.

On submission of the completed application, forms and documents to the regulator, we can support with preparation for interviews with the regulator through a combination of training, workshops and mock interviews.

Other specialist support / capabilities:

Providing advice on the regulatory permissions required to conduct services, assessing potential structuring solutions and supporting with the legal formation of a new entity.

Providing advice on optimal tax structuring and potential tax implications (indirect tax, corporate tax, product tax and transfer pricing) to support firms with the provision of services in line with the proposed business strategy.

Providing accounting advice on the implications of business strategy and any structuring changes on the accounting requirements for entities or groups.

Supporting with business transformation and strategic change in line with the provision of new business.

Supporting with data and technology transformation projects, developing the strategies and implementing systems that build business value and drive performance.

Post-authorisation support

With authorisation being a key step in the development of a new financial services firm or business line, we understand that firms may also require support to ensure they embed and continue to meet regulatory requirements and expectations. We can provide tailored assistance and ad hoc support to assist with post-authorisation regulatory enhancements, whether that be with risk and compliance, governance, reporting or other areas such as transformation.