FCA publishes tips on good asset management applications

The FCA has published examples of good and poor practice on how asset managers can improve applications for authorisation. It has higlighted several areas which tend to hold up applications.

• where firms cannot show they will be taking decisions on the firm’s business in the UK on a day to day basis, with effective supervision from the UK of all activities and senior managers being able to visit and work in the UK as necessary;
• firms underestimating what they need to do to supervised outsourced service providers;
• not properly assessing the risks their business model could pose to clients, including not having fully appreciated the impact of the Consumer Duty on the business;
• failing to identify how conflicts could arise, and how to prevent and manage them;
• not understanding who the clients are and therefore not being able to show how they will comply with the correct rules;
• failing to assess and explain how the redress and compensation schemes apply (or not);
• not clearly articulating how they will use new permissions, if applying for a VOP; and
• not providing the required draft fund documentation with their application.