The FCA want to see that you have got the substance of your governance right before you start to complete the form for them.
Clear Ownership of Regulatory Responsibility
Accountability – name a person. We expect a named individual to be accountable for compliance with the regulatory requirements applicable to your firm. This individual’s responsibilities should be clearly set out in a job description or in your firm’s governance charter.
A Workable Oversight Structure
A firm’s board or senior management structure must demonstrate active oversight of a firm’s business, as opposed to just a list of names. This will be demonstrated by minutes, decision logs and meeting records.
A Conflicts-of-Interest Policy with Records
Again, having a written conflicts policy in place is not sufficient. FCA Authorisation also expects to see that the conflicts policy has been used, and evidence of how any identified conflicts have been considered and dealt with in the end. See also adempi.co.uk/fca-authorisation.
Genuine Compliance Expertise, Not a Job Title
This seniority is required to act upon any findings from monitoring and review and further detail can be found on the FCA authorisation page of adempi.co.uk.
Risk Identification at Governance Level
Your firm should also demonstrate how risk is identified and escalated and have a risk register (or equivalent) that senior management actively reviews. The FCA’s guidance on fair treatment of customers looks at the governance culture within a firm as opposed to just the processes in place.
Get the substance right and the rest will follow.