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Paul McGerrigan: The authorisation process

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Paul McGerrigan: The authorisation process

Unless you have been living in a cave, you will be aware that the Financial Conduct Authority has now published its interpretation and requirements in relation to the implementation of the European Mortgage Credit Directive.

This was published on Friday 27th March and I am sure many of you spent a thoroughly enjoyable weekend reading through the 319 page document… it is a good job the Six Nations rugby championship was on the weekend before.

Like all significant changes to regulation (remember MCOB and ICOB), the task ahead can seem daunting and overwhelming, but like any large project it should be broken into manageable and distinctive parts.

The first part that we all must address is the authorisation process and I would like to address this in my latest post:

1.    Your current position
The first area to address is to be very clear on your current position with the regulator. What permissions do you have? Sounds obvious, but there are firms coming at this regulation from very different starting points.

The Policy Document has done a good job of clarifying the difference and the different options for firms in each position, so I would encourage you to refer to pages 20-23 in the document to help you.

2.    What do you need?
The second area to address is to be very clear on the activities and services you want to offer post regulation day. Again, this might sound obvious, but making the call is the only way you can identify your next steps, the timescales and the work you must do get authorised.
 
3.    Permissions
Once you know what you want to be post March, identify what permissions you will need to have in place (or at least have applied for) to ensure you can offer those activities and services post switch-over day, which has been clarified as 21st March 2016.
                        
4.    Deadline
You then need to identify and set in stone the application deadline to ensure you have applied for the relevant permissions in time.

5.    Proactivity
Plan, plan, plan – Make sure you and the team of people helping you with the process (internal or external) have set aside enough time to get the applications completed, reviewed, signed off by all the relevant people and of course, submitted!

I would encourage all firms, large or small, to at least consider or talk to external compliance specialists who have experience liaising with the Financial Conduct Authority on obtaining permissions. This may save you a lot of time and effort. You will of course have to consider the financial implications of seeking this help but you may find the investment pays for itself with the time and effort that is saved.

In the next blog, I will address the key changes for the new regime.  

Attributed to Paul McGerrigan, Chief Executive of Loan.co.uk





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