The application forms are publicly available via the FCA website, but the forms and guidance do not provide an indication as to how the FCA would like the application to be completed, and the FCA’s viewpoint in this regard changes over time.

The endgame of the application process is to demonstrate to the FCA that the applicant firm meets the threshold conditions for being FCA authorised and to a large extent the application process is an exercise of reading ‘between the lines’ in order to suss out how the FCA’s criteria for deciding whether or not a firm meets these conditions – this can only be achieved via involvement with multiple applications.

Collating and drafting the necessary paperwork and submitting your FCA application is time-consuming in and of itself (circa 2 months) and can be further delayed if the FCA poses a host of unnecessary questions. Furthermore, it is becoming increasingly likely that an application that is not ‘up-to-scratch’ would need to be withdrawn and re-submitted.

Our team of senior FCA compliance consultants have helped gain authorisation for over 500 firms to date and can help to ensure that you get authorised the first-time round.

The time it takes the FCA to process a FCA application ebbs and flows, albeit they have a statutory obligation to process within 12 months. Our FCA applications team has been project managing these applications since 2003. In their experience the following average timelines can be expected:

So in reality, the entire process is likely to take between 10 months and a year from start to finish, depending on how quickly you’re able to prepare your submission – our team of senior FCA compliance consultants have helped gain authorisation for over 500 firms to date and can help guide you in expediating this part of the process.

The FCA expects all applicant firms to be ‘ready, willing and organised’ to commence regulated activities. A half-completed application sends the signal that the firm does not have a coherent plan for becoming authorised and conducted regulated activities once authorised. The worst-case scenario is that the application would need to be withdrawn and re-submitted.

Notwithstanding this, certain aspects can be provided at a later date e.g. the identity of the firm’s auditor or final versions of fund offering memoranda.

This is simply untrue. The FCA will aim to deal with all applications fairly and in due turn.

For many firms, including asset managers and investment advisers, there is an alternative to FCA Authorisation, which involves operating under an FCA Regulatory Hosting license and leveraging the value and expertise of the Regulatory Host at the same time. This solution can be turned around within 2 to 3 months.

Dependent upon activities conducted, either your staff members would be ‘seconded’ into the Regulatory Host or your firm would become an Appointed Representative of the Regulatory Host.

Regulatory Hosting is attractive to firms that want to get up-and-running quickly, and within an organisation offering a robust regulatory infrastructure, who take care of risk, compliance and operational needs, and are responsible for the regulatory capital requirements.

This can either be a long-term quick-to-market solution where you remain seconded into the Regulatory Host or become an Appointed Representative of the Regulatory Host indefinitely, or a medium to short-term solution to expedite getting to market soonest, whereafter you proceed with your FCA application in parallel, and move off of the Regulatory Hosting platform when you receive your FCA Authorisation. Based on the current FCA application lead-times, this can gain you as much as 10 months of trading-time.

At RQC Group, we offer both FCA Authorisation and Regulatory Hosting solutions.