The pre-application stage
We find that meeting with prospective firms before they submit an application helps them to:
- understand the authorisation process and what happens at the various stages
- understand our expectations of firms, and in particular the PRA and FCA Threshold Conditions
- identify any particular concerns that the regulators might have early on, and help firms make an informed decision about whether to spend time and money on an application that may not progress further
- submit as complete an application as possible.
However, there is no statutory requirement to meet us before submitting an application. An application can be submitted at any time, and we will use our statutory powers as set out in the Financial Services and Markets Act (FSMA) to reach a decision.
For firms who are new to the regulatory environment (such as start-up firms), we generally aim to meet three times with firms:
- Initial meeting: This takes place after a firm submits its draft business plan. It provides an opportunity for firms to discuss their plan and ask the regulators (us and the FCA) questions about the authorisation process. The regulators will provide written feedback for the firm to respond to in its business plan.
- Feedback meeting: This takes place after a firm has submitted – and we have reviewed – its updated business plan. We will again provide feedback, which the firm will be expected to address in its business plan.
- Challenge session: This takes place just before a firm submits its application, with the aim of discussing its proposals in depth and with the regulators providing detailed challenge on the content of the firm’s near-final business plan. Firms will be expected to incorporate feedback from this session into their application.
Firms who have an existing relationship with us may not require as many meetings, and for small, less complex and established businesses we often find that one meeting achieves the aims as set out above.
Meetings are generally attended by both ourselves and the FCA and will typically be held at either the FCA’s or our offices in London. Exceptions will primarily be made for internationally headquartered firms.
To initiate a pre-application meeting, we would expect as a minimum an explanation of why a firm wants to be an authorised entity and the initial business proposition and strategy including, but not limited to, the:
- business plan – what products will be offered, how they will be offered and the target market
- sources of funding – how the business proposes to fund its activities, and whether there are any investors and/or funding in place
- corporate governance – details of structure, board, senior management and governance arrangements, as far as they are known.
We may ask for further information, such as information on the proposed controllers if relevant.
To request a pre-application meeting, a firm that has an existing relationship with us should contact their relevant supervisory contact. For those new to the regulatory environment, please email NewFirmAuthorisation@bankofengland.co.uk.
Pre-application: Lloyd’s managing agents
Firms applying as Lloyd's managing agents should have had detailed discussions with Lloyd’s before they submit an application to us. A pre-application meeting will depend on the specifics of the application, but it will usually involve Lloyd’s and the firm.
Pre-application: credit unions
We have specific requirements for credit union applicants’ business plans, which are set out in Credit union authorisation: supporting documents.
