CMCs: apply for FCA authorisation

Learn more about how to apply for FCA authorisation if you are a CMC.

When to apply

Once you have registered for temporary permission (TP), we will confirm which of 2 application periods you have been allocated.

Application period 1 (1 April-31 May 2019) is for:

  • CMCs that only do financial products and services claims work (but not CMCs who only do lead generation work)
  • CMCs new to CMC regulation (eg some Scottish firms or firms exclusively handling Section 75 claims)

Application period 2 (1 June-31 July 2019) is for all other CMCs. This will include:

  • CMCs that do financial services and product claims work and also do lead generation for non-financial services/products claims
  • CMCs that only do lead generation (regardless of sector)
  • CMCs operating in all other sectors
Firms that have a claims management TP but don’t send us an application form within the correct application period will have to stop claims management activity. They will have:
-to stop any new activity, and
-30 days to wind down their business and explain to existing customers how to continue claims without their help

 

Once you have submitted your application:

  1. We will email you to confirm we've received it.
  2. We will email separately to confirm it's been assigned to a case handler.
  3. The case handler will review your application and update you.

If your firm’s application is successful, you will need at least one individual approved to perform a Senior Management Function by 9 December 2019 (or the date at which your firm receives re-authorisation, whichever is later). Most pure CMCs will only require one individual to be approved, but larger firms (turnover of more than £1m) will require two. You will need to submit this application from 9 September 2019. It must be received by 9 November 2019 at the latest.

What an application must include

We need a range of information about your business, namely a business plan – which sets out your objectives, customers, employees, governance, plans and projections.

This is likely to include:

  • full explanation of your business, its background (including its legal structure and creation) and what it will do, including the sectors it wishes to operate in
  • objectives (eg, business opportunity, market share, aims)
  • details of your governance framework and key personnel
  • experience and employment background of your firm's principals and an explanation of how they are competent to perform the regulated activities you want to carry on
  • analysis of key conduct risks
  • any outsourcing plans or other key operational matters
  • your long-term strategy and financial projections for 3 years
  • where customers will be sourced from with details of any lead generators
  • any unregulated activities your business will perform
  • details of websites, promotions and communications

See financial services firms and authorisation.  

If your application is missing some of this information, we will ask you to fill in the gaps. This will delay the application process. 

Current Appointed Representatives

As a firm cannot be both authorised and exempt, any firms that are currently an Appointed Representative (AR) under the current FCA regime will need to decide how they wish to proceed. They can continue to be an AR while they have a claims management temporary permission but they will need to decide what they want to do by the end of their allocated landing slot. They have several options:

  • Stop being an AR for the regulated activity and apply for authorisation for both the CMC activity and the activity they performed as an AR.
  • Stop being an AR and performing that regulated activity.
  • Stop CMC activity and continue being an AR.
  • Establish another legal entity and apply to perform either the CMC activity or the AR activity.
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