FCA has updated its website to tell funeral plan providers and intermediaries what they need to do to ensure they are appropriately authorised by 29 July 2022. It has provided a set of forms that applicants will need to complete, whether it is for a new authorisation or a VOP, and given some guidance on what FCA will expect to see in the documents submitted in support of the application. It notes:
- the need to show the applicant will be ready on time to commence its regulated business;
- the importance of only applying for permissions that are needed;
- how FCA will assess the honesty, integrity and reputation of key members of staff and will look at how the applicant will comply with the SMCR;
- the need for a clear regulatory business plan, setting out the firm’s business model, key regulatory risks and how it will mitigate them, and how it will comply with regulatory obligations on an ongoing basis;
- that it needs to understand how the business will operate;
- it will want to see agreements with key service providers and understand how firms are building resilience, training and competency into their business models;
- that the application must clearly explain compliance policies and procedures;
- that providers will need to provide an “Asset Adequacy Report” as well as a solvency assessment report; and
- that applications cannot be submitted until all necessary documents have been completed.
FCA also notes that intermediaries may apply to become appointed representatives – and, in this case, their principals should be prepared to demonstrate in their VOP that they will have in place appropriate systems and controls to onboard, oversee and monitor their ARs