· Once an authorisation application has been submitted, it can take several weeks for a case handler to be appointed to the firm. This delay is not unusual
· Firms should not be surprised to be asked additional questions on their authorisation application. This is common and firms will need a process in place to deal with these within the deadlines or request extensions.
· Many firms are incorrectly calculating their ‘consumer credit income’, on which the FCA’s fees will be based. Double check this is correct at the outset.
· Make sure a suitable point of contact is included on the authorisation application. Too often this has proved to be someone who cannot readily deal with subsequent queries raised by the FCA. It needs to be someone of sufficient seniority.
· Make sure any statements, such as, ‘we are committed to treating customers fairly’ and ‘we will assess affordability’ are backed up by a description of the process. Many firms fail to do this.
· Set out the relationship with the customer from start to finish and be clear on what the pre-contractual information includes.
· A firm’s conduct throughout the authorisation process will be considered as part of the decision-making process.
The FCA will publish a further update in June on how the authorisation process is progressing.