What are the key changes?
The new process designates specific timelines for different stages of the application process and a more proportionate approach to the authorisation application process based on the activities intended to be carried out by the firm, its level of required regulatory capital and the individual structure, size and complexity of the proposed firm. It is hoped that the new process will allow for a speedier and more efficient authorisation process for MiFID firms.
One key change is the introduction by the Central Bank of a requirement that all applicants must provide an overview of its Business Continuity Plan. In particular, the Central Bank requires detail of:
- The proposed frequency of BCP testing
- When the BCP was last tested and a summary of the findings (if applicable)
- Details of the off-site disaster recovery area to be availed of by the applicant in the event of its premises becoming unusable
- How quickly the applicant will have access to all essential data and functions in the off-site disaster recovery area in order to recommence operations
- How regularly the applicant’s data will be backed up and where it will be held
- Arrangements for the use of an off-site disaster recovery area that is not a private residence to which the Central Bank will have unrestricted access if required