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Navigating the FCA authorisation process can be daunting, but with our expertise, we make it easy, simple, and straightforward. For businesses such as motor dealers, vets, dentists, and golf clubs that need secondary credit broking permissions, we provide a general step-by-step guide on how to apply for a consumer credit licence.

You would first need to correctly identify whether your business activities require Full Permission or Limited Permission. For example, motor dealers, dentists and vets may only need Limited Permission if their primary business isn't credit broking. More information about what consumer credit permissions are needed can be found online on the FCA’s website. Unfortunately, however, you would be unable to receive a definitive answer if you contact the FCA’s SupervisionHub / Customer Contact Centre, since their current employees are not allowed to provide you with advice but only ‘guidance’. For definitive advice, the FCA will ask you to seek your own compliance advice.

We at Alumni Compliance, however, are all former and not current FCA employees. This means we are able to confidently advise you and tell you exactly what permissions you need and don’t need for your business.

The FCA will expect you to complete a comprehensive Regulatory Business Plan (RBP) which that details your operations including the nature and scale of your business, financial information and forecasts including balance sheets and accounts submitted to Companies House, what risks your businesses potentially face and how you would mitigate them, systems and controls, policies, and compliance measures including your Compliance Monitoring Programme (CMP). All of this would help support your application and increase the chances of your business being authorised by the FCA if you show them that you are Ready, Willing, and Organised to be authorised and regulated.

The main authorisation application also includes supplementary forms such as the SMCR Approved Person form and the Statement of Responsibilities. These must be completed as a limited permission firm would need to appoint an individual who will hold the Senior Management Function (SMF29 Limited Scope Function) for the authorised business – the person responsible for regulatory oversight. 

For the proposed SMF29 candidate, a 10-year employment history would need to be provided, in addition to an employment reference, a Basic DBS Check, and a CV. All of this information is required by the FCA in order to demonstrate that the SFM29 candidate is fit and proper, and has no issues with their honesty, integrity, and reputation; competence and capability; and financial soundness. 

We would highly advise that you remain upfront and honest with the FCA concerning your individual background, previous employment, and any other issues concerning the FCA’s Fit and Proper criteria. If the FCA establish facts which you have not disclosed to them or have attempted to keep hidden from them, then you risk having your authorisation application rejected. If you would like to have a confidential chat with Alumni Compliance on how to navigate this issue if you believe there may be some sensitivities involved, please contact us. 

The Long Form A which needs to be completed can be found in the FCA’s Handbook.

You would need to register for the FCA Connect system as a new user of a firm that is not currently authorised by the FCA. This is so you complete and submit your authorisation application online as paper application or applications via email is not accepted by the FCA. With the Connect system you can save as you go along and complete it at your own pace and convenience.

After you’ve completed all sections of the main authorisation application, a non-refundable FCA authorisation application fee is payable directly to the FCA before you can submit your authorisation application. The Limited Permission application would cost you £500 and VAT is not applicable. Payment is made online to the FCA and can be done via a credit card or debit card.

If your application is rejected by the FCA, or voluntarily withdrawn by yourself, the application fee would not be refunded to you by the FCA. This is why it is very important to ensure you submit a correct, complete, and high-quality application so that there is no risk of the FCA rejecting your application and your business losing out on the fee.

From our previous experience as FCA staff and Case Officers working on authorisation applications, we have seen hundreds of firms unfortunately lose out on their application fee because their submissions had to be rejected for not being good enough, or because they did not submit a Basic DBS Check, for example. 

After submission of your application, it is a waiting game. Typically the FCA can take 1-3 months on average to process a Limited Permission consumer credit application, however, that is only if the original application is of a high-standard and is complete with all required documentation and evidence. 

If an application is not complete, there is crucial information missing, or clarification is required, the FCA Case Officer will contact you for the missing information or clarification and provide you with a deadline to do so. When they do this, the Case Officer will ‘stop the clock’ and will not progress your application until you’ve responded to the Case Officer with that they are seeking. If you fail to answer by their deadline, the FCA Case Officer will attempt to contact you again, however the timescale as to when your application would be approved would then be significantly increased, perhaps from 3-6 months, or even up to the maximum amount of time the FCA can take to process an application which is 12 months.

If you do not respond to an FCA Case Officer’s information or clarification request despite their attempts to contact you, then they will either reject your application or ask you to withdraw it with the application fee being non-refundable.

FCA Register Entry

After your business has been successfully authorised, your firm would appear on the FCA’s Financial Services Register. On display would be your firm name, your Firm Reference Number (FRN), company registration number, business address, firm contact details including phone, email and website, complaint contact details including the name of the nominated person for handling complaints, authorisation status and the permissions your business has to carry out regulated activities, and the details of the SMF29 (just the full name and the Individual Reference Number). Customers who search for your firm by the name, FRN or even the postcode, would then be able to see that your firm is authorised by the Financial Conduct Authority and therefore is able to legitimately carry out credit broking and other regulated activities applied for.

Registering for FCA Connect

The authorised firm would need to re-register for the FCA’s Connect system, this time as an authorised firm. By doing so, your firm would be able to submit any ad-hoc notifications and applications to the FCA, for example: to amend standing data and firm details, to add / remove / amend details of the SMF29, to amend regulatory permissions, or even to cancel your authorisation.

Registering for FCA RegData

In addition, the authorised firm would need to register for the FCA’s online regulatory reporting system, RegData. All authorised firms are required to submit regulatory reports to the FCA. For Limited Permission consumer credit businesses, this would be annually. It is important to submit your regulatory reports on time, as failure to do so would result in a £250 late return administrative fee. Consistent failure to submit report on time or pay the late return fee, could result in your authorisation being cancelled by the FCA.

Registering for FCA Online Invoicing

Authorised firms would also need to register for the FCA's invoicing system so that they can receive and pay their annual FCA invoices.

Annual FCA Fees

The Financial Conduct Authority is not paid for by the taxpayer. They operate from fees and levies raised by them from the entire regulated population of businesses from big, global banks and fund managers to a sole trader Independent Financial Adviser (IFA), everything from the sugar sachets to the FCA CEO’s salary is paid for by the industry.

Limited Permission consumer credit firms would also need to pay their annual fees to the FCA, and this based on how much regulated income your business has generated annually. If it is between £0-£10,000 then your FCA fee would be £350. The FCA have a useful annual fee calculator which you can use. 

Paying your annual FCA fee is important. Failure to do so could result in the FCA applying interest on outstanding fees, instructing debt collectors against you, and / or cancelling your FCA authorisation.

More information about the FCA's consumer credit broking authorisation process for firms such as 

• motor dealers
• vets
• dentists
• gyms
• golf clubs
• other secondary credit brokers

Can be found online on the FCA's website.