The types of firms we work with
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Credit Brokers
We have supported a wide range of credit broking clients across all major sectors since 2003, helping more than 800 credit firms get authorised by the FCA, manage their ongoing compliance obligations and reduce their regulatory risk.
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Leasing
With more than 360 credit clients currently benefitting from our ongoing support, we are well suited to support firms looking to carry out credit leasing activities. From helping them to achieve authorisation from the FCA to helping them to meet their ongoing compliance obligations.
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Lending
We can help new credit lenders get authorised by the FCA, manage their ongoing compliance, and help them to guarantee that the appropriate steps have been taken to ensure all senior managers meet FCA 'fit and proper' requirements.
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You might be interested in these services...
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Ongoing Compliance
Whether you’re seeking a compliance partner for the first time, or want to benchmark your current provider we offer a genuinely fresh perspective.
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Training
E-learning, classroom training and board briefings to help firms meet FCA training and competence obligations.
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FCA Authorisation
If you want to provide regulated financial services, we can help you avoid pitfalls and delays with your FCA authorisation application.
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What to expect from the FCA Authorisation process
In recent years, the level of scrutiny applied to firms seeking authorisation from the FCA has increased substantially across the board, and this is particularly prevalent in the consumer fiance sector. Historically, there were no requirements to provide business plans, financial forecasts, or detailed policies and procedures and interaction between FCA case officers and applicant firms was minimal. Over time this has changed, and firms now looking to get authorised should be aware of the extent of information the regulator will be looking for and the scrutiny it will be applying to these applications.
Cosegic has helped more than 800 credit firms to submit successful FCA authorisation applications and are well versed in the requirements bestowed upon firms looking to get authorised, how this has changed over the years, and what firms should be doing to prepare. To help firms looking to get authorised for the first time, we have put together a short list of the core requirements of the authorisation application that have been introduced over the years.
Authorisation Requirements:
Financial Forecasting
The FCA requires a 3 year forecast covering both the regulated activity and non-regulated activity the firm intends to operate. Complete P&L, balance sheet and cash flow forecasts must be submitted and these must cross validate. The forecasts must be well thought out, realistic and achievable. How the business is being funded should be very clear and how any investment of funds is introduced to the balance sheet as well as accounting for expected repayment of the debt. Where a firm has a minimum capital requirement this must be in place from day one.
Policies
All policies must be tailored to the applicant firm. Whilst it is accepted that policies start life as a template, these must reflect the size and structure of the firm and be realistically implementable. As an example, if a complaints policy referred to customer complaint team at head office; however the firm was a small single site car dealership, it clearly would not align with the business model.
Read the FCA guidance
The FCA have been very open regarding the required documents needed to support the application as well as providing guidance on what these documents should include within its content. This will help reduce the number of questions that the firm will receive. The firm must understand the application, its content, and how it will be implemented. Whilst using the services of a compliance consultant or a law firm to assist with building the application is common practice, the FCA now conducts competency interviews with applicant firms. The directors of the firm must therefore be fully aware of their regulatory responsibilities, the content of the application and the policies they intend to implement.
Consumer Duty
The applicant firm must be able to demonstrate a clear understanding of their responsibilities in meeting the Consumer Duty. Firms need to consider how they will monitor customer outcomes and make provisions for this within their resources and compliance monitoring plan. Find out more about our support options here.
Don’t underestimate
It is easy to refer to becoming authorised as registration process. The two are very different in every sense. The FCA have a responsibility as the conduct regulator to be challenging and robust in their assessment of whether a firm is ready, willing and organised. Where firms fails to become authorised, this is often due a naivety about the process and an underestimation of the importance of demonstrating the firm and its directors understand their responsibility.
If you are looking to get authorised and require support with any of the above items, we would be happy to open a discussion with you. Take a look at our support options here.
