Our Services

FCA Authorisation and other applications

 

We can help you obtain an FCA licence (Part 4A permission) as part of an FCA authorisation application. We can assist with other submissions to the regulator such as Variation of Permission (VoP) or change in control (which can be required as part of a restructure or change in business model).

Our service is fully flexible; we can project manage an application and ‘hold the pen’ drafting documents or offer a review and advice service for a more affordable approach. This includes initial scrutiny of the basic essentials.

We are often tasked with the following:

  • Reviewing and assessing the regulated activities conducted by the applicant, the ‘Scope of Permission’ required and the applicant’s prudential category (a critical task)

  • General assistance with the CONNECT system through which applications are submitted

  • Assistance with identifying and completing all necessary FCA forms and supporting documents (the business plan is key)

  • Provision of the draft compliance infrastructure necessary to commence business (some of which needs be submitted with the FCA application)

  • Assisting with the preparation of financial and regulatory capital projections (where there are additional obligations such as an ICAAP or wind-down plan we can also assist)

  • Help with individual Senior Manager applications and supplementary documentation (such as the Learning and Development plan)

  • Provide training on all aspects of the application process, the Threshold Conditions (the minimum conditions to be and remain authorised) and the Senior Managers regime.

  • We also provide bespoke Compliance Officer and MLRO training tailored for the firm and the individual

  • Assisting with questions from the FCA during the application process (including discussing timescales, approach and next steps)

 We are also happy to provide a short session summarising key actions following FCA authorisation (which builds on information supplied by the regulator) such as walking through FCA reporting, registration for key FCA systems, FCA fees cycle and compliance monitoring.

Assisting Compliance Consultancies

 

Our staff have acted as in-house technical experts at various consultancies, and we now offer support to these and other Compliance Consultancies where they require technical assistance or additional resource.

Our team includes experienced individuals who have in depth technical knowledge and excellent consulting skills (being ex regulators and consultants of many years). Such individuals can accommodate flexible working arrangements helping team members deal with individual queries or working as part of a project group delivering on workstreams.

Staff can provide support to individual clients (with appropriate restrictive covenants and NDAs) under a ‘white label’ arrangement or are happy to help answer individual questions where specific technical knowledge is needed.

Our expertise and skill set lends itself to helping with individual client queries, assisting with applications or supporting your staff. Speak to us to discuss your needs.

Help and advice for regulated firms

 

Maybe you are seeking FCA authorisation, are newly authorised, or a compliance veteran in a well resourced team. We will offer a pragmatic service which suits you and your firm.

We prefer an ongoing engagement. This gives us the flexibility to help manage your compliance risk when needed (flagging new FCA initiatives or important rule changes for instance), while also helping us budget and manage our resources as a consultancy. That is important for us and our clients - You need consultants who are available to assist when you need them…not consultants tied up with other clients or working on projects elsewhere, unavailable for weeks.

We do not have a minimum number of hours or commitment; this gives us flexibility to work with start ups, small firms with tight budgets and larger firms who only need occasional help.

If you would like an ad hoc engagement we will happily support this, and we understand that sometimes you just need the option to ‘phone a friend’. If we don’t feel this service is right for your needs we will tell you and explain why, pointing to the areas of regulatory risk we think you are exposed.

Our services are highly competitive. Our business model is lean and flexible, and will remain so. We have few overheads, and no external shareholders demanding a certain margin, enabling us to employ the best consultants and still charge competitive rates.

In house support (Secondments, Compliance Monitoring, Regulatory projects and SMF 16 / 17)

 

Sometimes regulated firms need more support. Even the best laid plans can go awry, or for some this may be a strategic decision. For firms planning contingencies, who need support right now, covering leave or tackling a specific issue…we can help. Our consultants have all worked in house on long term secondments, fulfilled compliance monitoring or focused on helping complete compliance projects.

We can be part of your ‘back up planning’ for contingencies…including when drafting wind down plans. For short periods of time we can provide experienced individuals who can act as SMF 16/17, where this is right for our consultants and your firm alongside appropriate communications with the regulator.

For firms who would like support with designing, implementing and fulfilling compliance monitoring requirements we can do so. On a continual basis or for short periods of time.

If you simply need extra resource in the compliance function (to cover leave, sickness or help tackle regulatory projects) we can assist.

Training

 

All regulated firms have requirements to provide training to their staff. There are regulatory and legal obligations to provide training on certain topics on a regular basis. All our consultants are experienced at training delivery on a range of topics. Several of our consultants have even designed and delivered training for the regulator in their formative years at the FCA.

We are skilled at undertaking training needs analysis; designing and delivering bespoke training where this is required, for individuals or groups. We can call on external training experts to assist in this process, working with them to ensure it reflects the relevant level of technical knowledge.

Where clients prefer us to use standard training material (on financial crime, SMCR, SMF 16/17 for example) to reduce costs we will, which we can then tailor for your business model, the needs of attendees and update with the latest and best examples of good and bad practice so you and attendees get the best out of the experience of working with us.

Regulatory projects

 

When it comes to regulation, it seems the only constant is change. There is a smorgasbord of acronyms to prove this. Some of the more memorable are AIFMD (and the upcoming AIFMD II), MiFID II, PRIIPS, EMIR, SFTR, GDPR, MLD5 and of course IFPR/CRD, and not forgetting SMCR.

Our staff have helped firms through this regulatory journey. Distilling the essential information and actions require to comply and outlining the steps needed. Creating tools and summaries. And when required, managing this change alongside clients or taking a more hands on role.

We can review your implementation of changes in response to previous regulatory change projects. Or we can help to address upcoming regulatory change (for example, on IFPR) from impact assessments, gap analysis through to training and implementation.

Regulatory reviews (Health checks)

 

Firms and individuals can request a review of a regulated firm’s compliance oversight function. This may be a wide ranging review of the entire compliance function or a focused review of a specific area.

The purpose of such reviews can be many. The outcome should be a report setting out the effectiveness of the compliance function (from high-level requirements such as conduct and culture as well as specific rules and best practice) with tangible actions to make improvements or take remedial action.

Such reviews may be requested by Senior Managers / the governing body of a firm as they may have concerns, or just lack information to make an adequate assessment of the compliance function. It may be driven by a change in people (incoming SMF 16/17 or new CEO/COO). There may be external drivers such as due diligence requests. Or perhaps there are near misses / clear breaches, where such a review would provide assurance these are isolated instances, or that remediation projects have been successfully completed. For some firms it is simply best practice to undertake a health check on a regular basis (particularly smaller firms with less resources and no audit function).

Whatever the underlying background or area, we can help. Our staff have conducted many health checks and deep dive exercises. We find SMF 16/17 holders and the Board especially welcome our feedback meetings and the practical discussions held as part of this work.

We are happy to discuss this topic further.