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Thought Leadership

FCA changes its Form A (Approved Persons Application) questions on its Connect portal ahead of SM&CR

Posted on 21 Nov 2019

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The FCA has recently changed the content of its Form A (Approved Persons Application).

A month ago, Laven’s Associate Director, Elizabeth Frumson, sent a notification via email, to the FCA with the aim of providing clarity on the Form A’s available on Connect. Namely, whether the Form A’s new wording is applicable to approved persons being registered under the Appointed Representatives Regime. The previous wording simply asked firms “Do you want the candidate to be approved on or after 9 December 2019?”.

We were keen to understand whether we should be selecting ‘yes’ or ‘no’ in regard to approved persons under our Appointed Representative umbrella who need to hold a controlled function after the 9th of December.

Like many other firms, we applied with the view to have all approved persons registered after the 9th of December. As such, the preliminary question of whether a candidate should be regulated on or after the 9th of December caused confusion among several regulated firms.

Understandably, the intentions of the FCA is to ensure firms start implementing the new changes posed by SM&CR for the approval of any SMF’s already. However, the new SM&CR rules will not apply to appointed representatives which caused confusion to firms registering approved persons under Appointed Representative Regime.

As such, Laven recommended for the FCA to clarify in its forms the course of action a firm should take in relation to the registration of its approved persons.  We are pleased to have recently found the small, but useful addition the FCA has provided in its Form A’s which now states: “Please note if you are only applying for an individual to hold a CF(AR) functions, please select ‘No’”.

Are you ready for SM&CR implementation date? Laven is offering a 25% off its SM&CR package to make sure you have all the necessary documents and procedures in place ahead of the end of the implementation period. To find out more information click here.