Authorisation Landing Slots – Opening Soon
1 December 2014 marks the date that authorisations open for most High Cost Short Term lenders. Be under no illusions about the seriousness of this process. Some clients have looked at the Interim Permissions process and think that getting Fully Authorised will be a similar process. The fact is that there was no real checks before issuing Interim Permissions and there is a real risk to your business that you might not achieve full authorisation. Whatever your landing slot, you should be getting your application ready NOW, and the high level risks associated with putting everything together at the last minute is that:
a. You will have an incomplete application. The FCA has said that it will respond within six months to a completed application. This automatically moves to a year if your application is incomplete.
b. You lose your ability to have a two-way relationship with the FCA. If you put your application in in early December then you have nearly three months of negotiation with the FCA to get them to understand your business and to show you are a responsible lender. If you wait until 28 February then the relationship becomes one-sided. You can no longer continue to provide information to the FCA when you want to and any requests for information are only from them and on their time line.
Policies, procedures and your Regulatory Business Plan are all intrinsic to your application. Alph Legal can provide you with off-the-shelf policies, ongoing compliance as part of your Compliance Plan and are happy to review every part of your application and give you guidance in relation to this.
We have some planning tools available that may help you to detail the process. Please contact us if you are interested in our free tools.