EEA Firms: Key Questions To Address

Posted on: 15 April 2021

Written by: James Borley


Below we summarise some of the key questions which will have to be addressed when considering an application. There are potentially many other questions and we are on hand to offer advice and guidance should you need any assistance with your application. 

Does authorisation make sense for our UK business?

  • Will it be profitable and likely to succeed? This should take into account the market in which you intend to operate and your firm's ability to meet the relevant capital requirements, on an initial and an ongoing basis.

Is our UK business a branch or a subsidiary?

  • If the business is a branch, does it need to be a subsidiary to apply?

  • How will changing to a subsidiary affect the capital requirements of the business?

  • Does it make financial sense for my business to apply for authorisation?

 How will the FCA view our firm’s ability to be regulated?

  • What is the extent to which the FCA is able to supervise the conduct of your firm’s UK business?

  • What would the FCA perceive the potential outcomes in an insolvency situation to be?

  • What is the supervisory cooperation relationship like with your firm’s Home State regulator, for both the firm and for the FCA?

What is the FCA’s view of your retail harm risk, wholesale harm risk and client asset harm risk?

  • How can your firm help to mitigate those risks?

What resources does your UK business need to have in place to meet the FCA authorisation requirements?

  • This includes human resources and expertise, capital, technology, and a location within the UK. For example, does your firm have sufficient knowledge, skills and experience to meet regulatory expectations?

  • Does your firm have the right internal controls framework in place, including governance, risk management, compliance and prudential requirements?

How does the regulator view firms with similar business models?

  • How might the regulator regard your business model?

  • What changes should you make in advance of your application?


James B

James Borley

James, our Managing Director for Payment Services, is a highly qualified financial services expert and a familiar name to many in the payments and e-money community.

Contact James

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