The FCA has published guidance on the steps it takes when assessing applications from firms applying for full permissions.

The process is principally split into stages as follows:

  • Review stage
    • Assessment of whether the application is complete.
    • Review of the firm’s structure, including its resources and management systems, with focus on key people such as controllers and approved persons.
    • Cross-check of information disclosed against various databases and information held by other regulatory agencies.
    • Assessment of the firm’s business model and compliance with the FCA’s Handbook and Consumer Credit Sourcebook.
    • Assessment of how the firm engages with its customers.
    • If necessary, a visit to the firm.
  • The FCA’s authorisation team recommends a decision to grant or refuse the application.
  • The application is referred to the FCA’s Regulatory Transaction Committee for a decision.
  • If the decision is to authorise the firm, it receives written confirmation and a “Scope of Permission” notice, and both the Financial Services Register and Consumer Credit Permissions Register are updated to show that the firm is “fully authorised”.

If the decision is to refuse the application, a Warning Notice is sent to the firm. The firm can contest the decision by making oral/written representations to the Regulatory Decisions Committee (RDC). The FCA will issue a Decision Notice if the firm does not make any representations, or the RDC considers that the application should be refused. Firms may then refer matters to the Upper Tribunal.