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FCA Authorisation Solutions for the UK Authorised and Recognised Funds | Pre-licensing Support | FCA Authorisation Application Management | Post-licensing Risk and Compliance Solutions

We offer a comprehensive set of solutions to help you obtain and maintain an FCA P2P Lenders' Authorisation issued by the UK Financial Conduct Authority (FCA), tailored to:

Your business goals and objectives
Your client demographics
Your countries of operation
The size of your business
The available human and technology resources
Your risk appetite
Your governance structure
The products that you offer
FCA Authorised CIS Managers’ Obligations: covering risk and compliance management under financial laws and regulations, the applicable financial licensing requirements, AML/CFT laws, privacy laws, consumer protection laws, and more

We have designed our financial licensing solutions to help you navigate the complexities of the FCA CIS authorisation framework in a commercially oriented and goal-focused manner, providing effective support for all stages of the FCA fund authorisation process, including but not limited to the following aspects:

FCA CIS Authorisation Guidance: Advising on a wide range of aspects associated with an FCA fund authorisation as it relates to your specific situation
Pre-licensing assessment: Covering compliance gap analysis as well as risk and compliance assessment
Pre-licensing support:
Drafting the necessary policies and procedures to help you comply with the FCA fund authorisation conditions and financial markets' regulations
Developing internal controls to help you meet your obligations under the FCA CIS authorisation framework
FCA CIS Authorisation Application Support: Covering the entire licensing process
Post-licensing Support: Covering
Ongoing compliance advice
Comprehensive second-line risk and compliance support, including leading the implementation of your risk management framework (RMF), compliance management framework (CMF), compliance monitoring program (CMP), compliance calendar and checklist, ongoing risk assessments, internal and external reporting, outsourced providers' management, and more
AML/CFT advice
AML/CFT compliance management
Compliance assurance solutions, including compliance assurance program (CAP) development, implementation, and internal control testing

Service Coverage

This page is about the UK FCA CIS Authorisation covering authorised and recognised funds. According to the FCA:

"An authorised fund, which may also be called an ‘authorised CIS’, must be established in the UK and take one of the following legal forms:

authorised contractual scheme (ACS)
authorised unit trust (AUT)
investment company with variable capital (ICVC)
It must also be classified, based on a marketing strategy, as one of the following:

undertaking for collective investment in transferable securities scheme (UCITS)
non-UCITS retail scheme (NURS)
qualified investor scheme (QIS)
long-term asset fund (LTAF)"

In addition to FCA fund authorisation, we also provide licensing and compliance solutions to:

UK wealth managers and consumer investment firms. For more information, please visit our UK Consumer Investment Firms' Authorisation Page.
Fund managers in other jurisdictions. For more information, please visit our Fund Managers' Licensing Solutions Page.

FCA Fund Authorisation Preparation

Pre-licensing Compliance Assurance

Our FCA CIS authorisation solutions cover the following focus areas:

Compliance Goals Analysis: We review your business-specific goals and resources against the suitability criteria for the FCA CIS authorisation framework
Initial Consultation: We provide guidance on potential risk and compliance issues that may arise during the FCA fund authorisation process
Choosing the Right Jurisdiction: We assist in evaluating regulatory, risk, and compliance environments to determine the most suitable jurisdictions for your FCA CIS authorisation, tailored to suit your:

business objectives,
operational capacity,
client base,
markets of operations,
and other relevant factors

Gap Analysis: We identify gaps between your existing operations and regulatory requirements and help you align them in a commercially oriented manner
FCA CIS Authorisation Application Plan: We help you establish a roadmap to effectively meet the FCA fund authorisation requirements

FCA Fund Authorisation Guidance

Selecting the right compliance model is crucial not only for navigating the licensing process but also for maintaining ongoing compliance and avoiding potential breaches. Our FCA CIS authorisation solution covers:

Compliance Model Selection: To help you best comply with the FCA CIS authorisation framework and related risk and compliance obligations.
Corporate Governance Model Selection: We offer practical guidance on establishing effective corporate governance practices that support your risk and compliance oversight.
Operations Model Advisory: We advise you on optimising your operational and governance models to help you efficiently comply with the FCA CIS authorisation framework, keeping in mind your specific circumstances, available resources and business goals.

Entering the ASIC Regulated Environment

We help businesses transition from an unregulated environment to operating under the FCA CIS authorisation framework, helping them meet their obligations as FCA CIS authorisation holders.

We also assist already regulated businesses in aligning their existing risk and compliance management structures with the requirements of the FCA CIS authorisation framework.

Our focus areas for this service include:

New businesses
Existing MIS managers operating in unregulated markets
Regulated MIS managers expanding into foreign jurisdictions
Financial institutions and/or service providers with established risk and compliance frameworks seeking to introduce regulated custody services trading as a new product.

Multi-Jurisdictional Compliance

With years of experience managing risk and compliance obligations for businesses operating under multiple financial licences across various jurisdictions, we help businesses remain compliant with the fund managers’ obligations globally.

FCA Authorisation and Wholesale Markets

Securing FCA authorisation for operating a retail collective investment scheme (CIS) may not always align with your business objectives. If your strategy is focused on engaging professional or wholesale investors rather than the broader retail market, pursuing retail product authorisation might not be the best fit.

In the UK, regardless of whether you serve retail or wholesale clients, any firm undertaking regulated activities must obtain authorisation under Part 4A of FSMA. However, if your business exclusively targets wholesale (i.e. professional, eligible, or institutional) investors, you can structure your activities and marketing accordingly so that you avoid many of the retail-specific product disclosure and client protection obligations.

We provide a broad range of risk and compliance management solutions to support UK investment firms that:

Focus exclusively on wholesale markets by targeting sophisticated, eligible, and professional investors.
Operate under the framework for regulated activities using firm-level authorisation (via FCA Part 4A permissions) rather than pursuing retail fund authorisation.
Align their operations with the requirements set for non-retail services while still meeting the full set of regulated activities.

Our services help these firms comply with regulatory requirements that extend beyond the product authorisation itself, including:

Complying with FCA Advertising Rules.
Adhering to fair dealing and client communication standards.
Implementing robust risk management frameworks.
Overseeing outsourced service providers effectively.
Ensuring the firm does not inadvertently offer regulated services to retail investors without the appropriate permissions.
Meeting obligations under Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) laws.
Complying with data management and other relevant legislative requirements.

FCA CIS Authorisation Application

We assist with your licence application through ongoing engagement in the FCA fund authorisation process:

Document Compilation and Review: We compile and review all required supporting documents to support your FCA CIS authorisation application.
Application Form Completion: We help you complete the forms so that all material information is accurate and complete.
Pre-Submission Review: We can arrange a pre-submission review session with key stakeholders to ensure all parts of your application are understood and agreed upon. This session aligns application details with the actual situation, removing ambiguity.
Regulatory Liaison: We manage the end-to-end submission process, maintaining clear and effective communication channels throughout the ASIC licensing process.
Timeline Management: We closely monitor and adhere to all necessary deadlines, providing timely updates and adjustments to keep the application process on track.

Resolving MIS Manager’s FCA Authorisation Issues

Having competent compliance advisors is crucial when licensing issues arise. Therefore, our FCA fund authorisation solutions include a range of services to address and resolve these issues effectively:

Remediation Solutions for FCA CIS Authorisation Applicants: We address and remediate risk and compliance issues identified by regulators, helping your operations align with the requirements of the FCA CIS authorisation framework.
Specific Licence Conditions Compliance: We can help you manage additional conditions imposed on your FCA CIS authorisation developing a tailored action plan to maintain compliance and facilitate the eventual removal of these conditions with minimal disruption to your business operations.
Licensing Issues Handling: We address common licensing issues encountered during the FCA fund authorisation process, providing you with solutions to navigate and resolve these challenges efficiently.
Further Information: You can visit our Compliance Remediation Solutions page for more information.

Post-Licensing Support

We offer a full range of ongoing risk and compliance solutions for ASIC-licensed MIS managers. Our services include, but are not limited to:

Ongoing Risk and Regulatory Compliance

FCA Authorised CIS Managers’ Obligations Guidance: We can advise your risk, compliance, management and other teams on meeting the requirements of the FCA CIS authorisation framework and other regulatory compliance obligations. You can visit our Compliance Consultancy Service page for more information.
Regulatory Risk and Compliance Management: We provide dedicated compliance managers to manage your overall compliance. For more information, visit our Specialised Compliance Management Solutions page for Fund Managers.
Compliance Assurance Solutions: As part of our compliance assurance solutions, we offer:

Compliance Assurance Program (CAP) development and testing options
Internal Controls Design option
Internal Controls Testing option
Internal AML/CFT Review option
Statutory AML/CFT Audit option

Compliance Training Solutions: We offer training programs to different teams on complying with:

FCA Authorised CIS managers’ obligations for risk and regulatory compliance management. You can visit our Compliance Training page for more information.
FCA Authorised CIS Managers’ AML/CFT obligations and operational best practices for fraud prevention. You can visit our AML/CFT Training page for more information.
Crisis Management Planning: We can develop proactive strategies to manage potential compliance crises effectively.
Anti-Money Laundering (AML) and Counter Terrorist Financing Solutions: We provide a full range of AML/CFT solutions for MIS providers. For more information, visit our Specialised AML/CFT Solutions page for Fund Managers.
Advanced Compliance Technologies: We can assist you with selecting and integrating advanced technology solutions, such as compliance automation tools and regulatory technology (RegTech), to streamline compliance processes without disrupting operations.

Risk and Compliance Framework Adjustments: Including adjustments to risk management frameworks (RMFs), compliance monitoring programs (CMPs), compliance management frameworks (CMFs), and other core procedures and policies to align them with:
new business goals
regulatory changes
changes in your operations
evolving market conditions
changes in stakeholders’ risk appetites (your banking partners, insurance companies, liquidity providers, etc.).

Risk and Compliance Obligations for FCA Authorised CIS Managers

FCA Authorised CIS managers are subject to various obligations set out in applicable laws and regulations. They are also expected to uphold standards for their conduct and internal operations, as outlined in regulatory guidance or accepted industry practices.

We can help you address these obligations and expectations through comprehensive support in different areas. The list below is not exhaustive:

FCA CIS Authorisation and Regulatory Compliance Obligations

Compliance Management Systems: We can help you establish effective compliance programs, compliance monitoring plans, controls testing methodologies, compliance calendars and more (covered under SYSC 6.1).
Risk Management Frameworks: We can help you develop comprehensive risk management frameworks to fulfil FCA Authorised CIS managers’ obligations for identifying, assessing, and mitigating operational, regulatory, strategic, financial and other types of risks (covered under SYSC 7.1 ).
Policy and Procedure Development: We can help you draft and implement policies and procedures aligned with the FCA fund authorisation requirements.
Compliance Monitoring Plans: We can oversee the execution of your CMPs, covering ongoing monitoring of your compliance obligations under the FCA CIS authorisation framework.
Internal Control Testing and Compliance Assurance: We can conduct internal reviews and audits of your controls to test their effectiveness and compliance with the applicable regulatory standards.
Capital Adequacy Requirements: We can help you implement controls to comply with capital adequacy requirements, helping your businesses meet FCA Authorised CIS managers’ obligations for maintaining required financial resources (covered under IFPR).
Liquidity Management Requirements: We can assist you in developing controls to comply with liquidity management requirements (covered under FUND 3.6.2R for AIFMs and COLL 6.6.3R for UCITS schemes).
Financial Auditing Standards: We can assist in establishing procedures to help you comply with the audit and assurance requirements under the FCA CIS authorisation framework.
Digital Payment Token Services: We can assist in developing controls to comply with regulations for digital payment tokens, cryptocurrencies, and digital assets, including obligations under the FCA CIS authorisation framework and AML/CFT requirements for transaction monitoring and reporting.
Compliance with Constitution and Compliance Plan Obligations: We can help you implement controls to support your compliance with the MIS constitution and compliance plan obligations, including procedures for scheme operations, monitoring mechanisms, and required documentation to meet ASIC’s expectations for Responsible Entities under the Corporations Act.
Records Management and Accessibility: We can help you with your record-keeping requirements for management and retention of relevant records (covered under SYSC 9).
Governance Notification Obligations: We can help you develop controls to maintain governance and compliance arrangements at or above the standards advised during licensing (covered under SUP 15).

P2P Lending FCA Authorisation and Regulatory Compliance Obligations

Compliance Management Systems: We can help you establish effective compliance programs, compliance monitoring plans, controls testing methodologies, compliance calendars and more (as required under FCA Handbook).
Risk Management Frameworks: We can help you develop comprehensive risk management frameworks to fulfil FCA regulated P2P lending platforms’ obligations for identifying, assessing, and mitigating operational, regulatory, strategic, financial and other types of risks
Policy and Procedure Development: We can help you draft and implement policies and procedures aligned with the UK P2P lending platforms' licensing requirements (as required under COBS Handbook ).
Compliance Monitoring Plans: We can oversee the execution of your CMPs, covering ongoing monitoring of your compliance obligations under the FCA framework for P2P lending platforms.
Internal Control Testing and Compliance Assurance: We can conduct internal reviews and audits of your controls to test their effectiveness and compliance with the applicable regulatory standards.
Capital Adequacy Requirements: We can help you implement controls to comply with capital adequacy requirements, helping your businesses meet FCA regulated P2P lending platforms' obligations for maintaining required financial resources (as required under IFPRU Sourcebook).
Financial Auditing Standards: We can assist in establishing procedures to help you comply with the audit and assurance requirements under the FCA framework for P2P lending platforms (as required under the SUP Sourcebook).
Digital Payment Token Services: We can assist in developing controls to comply with regulations for digital payment tokens, cryptocurrencies, and digital assets, including obligations under the FCA framework for P2P lending platforms and AML/CFT requirements for transaction monitoring and reporting (see FCA's Cryptoassets Guidance for more).
Investor Classification and Eligibility Controls: We can help you implement processes to assess investor eligibility and classification (e.g. retail vs wholesale/sophisticated), in line with the UK P2P lending limits, onboarding obligations, and investment caps.
Offer Document and Disclosure Controls: We can help you implement controls for preparing and issuing offer documents or pitch materials, including jurisdiction-specific disclosure requirements under relevant P2P lending or securities legislation.
Credit Intermediation and Credit Licensing Risk: We can help you prepare controls and procedures to manage credit licensing risks where your platform activities may fall within the scope of credit assistance under the National Consumer Credit Protection Act 2009 (as may be required under CONC Sourcebook).

P2P Lending FCA Authorisation and Operational Oversight Obligations

Oversight of Outsourcing: We can establish a set of effective controls to comply with the UK P2P lending platforms’ licensing obligations for overseeing outsourced services (as required under RG 104 and RG 105), also covering related obligations under AML/CTF compliance, ISO requirements, and more.
Structures for Governance: We can help you establish effective governance structures to comply with FCA regulated P2P lending platforms' obligations and develop an effective approach to overseeing your risk exposure and compliance status across different functions of your business.
Senior Management Accountability: We can help you comply with FCA regulated P2P lending platforms’ obligations for senior management and key staff conduct and competence.
Maintaining Operational Resilience: We assist in developing continuity plans to meet FCA regulated P2P lending platforms’ obligations for operational resilience, helping critical business services withstand disruptions (as required under the FCA Operational Resilience Requirements).
Managing Technology Risks: We provide guidance on technology risk management obligations under the FCA framework for P2P lending platforms.
Platform Access and Due Diligence on Borrowers: We can help you develop onboarding, due diligence, and monitoring controls for businesses or issuers raising funds through your platform, including AML/CTF obligations, background checks, and suitability assessments (as may be required under the FG20/1: FCA's framework for Assessing Adequate Financial Resources).
Dual-Sided Platform Conflict Controls: We can help you develop documented procedures to identify and oversee conflicts of interest where your platform facilitates both lending and borrowing activity (as required under RG 104).
Contract Structure and Licensing Exposure: We can help you assess your lending structure and document controls where nominee, trust-based, or custodial arrangements may trigger additional FCA authorisations.

P2P Lending FCA Authorisation and Market Integrity/Transparency Requirements

Standards for Market Conduct: We can help you implement controls for FCA regulated P2P lending platforms’ obligations to maintain fair and transparent market conduct, including preventing manipulation and insider trading.
Principles for Fair Treatment: We can help you implement controls to comply with expectations that cover adherence to principles of fair treatment and transparent communications with clients.
Standards for Conduct and Disclosure: We can help you comply with the UK P2P lending platforms’ licensing standards for conduct and disclosure.
Product Suitability and Governance: We can establish tailored controls to help licensed P2P lending platforms comply with product suitability obligations.
Protection of Client Assets: Where escrow is outsourced or not in scope, we can help you comply with P2P lending platforms' licensing obligations to protect and segregate client assets.
Resolution of Disputes: We can help you establish effective mechanisms for dispute resolution and complaints management, particularly for retail clients (as required under RG 271).
Advertising and Communications Oversight: We can help you develop controls for your marketing and promotional materials to ensure compliance with restrictions on advertising P2P lending offers, including social media monitoring and fair representation of investment risks (as may be required under the FG15/4: FCA's Guidance on Social Media and Customer Communications).

P2P Lending FCA Authorisation and Resource Management Obligations

We can help you comply with the following requirements of the FCA framework for P2P lending platforms:

Adequacy of Resources: Covering financial, technological, human and other resources.
Competence of Professionals: Covering key personnel, their necessary skills, knowledge, and professional competence.
Our focus areas include:

Assessment and Gap Analysis: We can help you evaluate the adequacy of your financial, technological, and human resources against the requirements of the licensing regime.
Resource Allocation Plans: We can help you develop strategies to optimise resource allocation, covering sufficient capacity for compliance, trading, operations, banking, customer support and other functions and departments.
Technological Solutions: We can recommend and implement RegTech tools to streamline compliance processes, such as transaction monitoring, reporting, and audit trails.
Staff Vetting and Rescreening: We can help you develop a framework for vetting and rescreening staff in line with the requirements of the FCA authorisation regime (see Senior Managers and Certification Regime), AML/CFT laws, and other applicable regulations, with checks calibrated to the level of risk and responsibility associated with each role.
Key Personnel Assessment: We can help you assess key personnel's skills, qualifications, and experience to identify areas for improvement.
Training and Development Programs: We can design and deliver targeted compliance training programs to upskill personnel in compliance, risk management, and P2P lending regulations.
Compliance Monitoring: We can help develop controls to monitor representatives' adherence to conduct and disclosure obligations.
Ongoing Training: We can help you create a framework to support continuous education for advisors and representatives on licensing obligations, market integrity, and client interaction standards.
Regulator Liaison: We can act as an intermediary with regulators to address queries and help you demonstrate compliance with resourcing obligations.
Investment Cap and Transaction Limits Controls: We can help you implement automated and manual controls to monitor investor contribution limits, deal caps, and maximum investment thresholds required by the licensing regime.
MIS and Custodial Licensing Triggers: We can help you assess your platform structure and prepare controls to address licensing triggers where pooled funds or trustee arrangements may require authorisation to operate a managed investment scheme or custodial service (as required under RG 132 and Corporations Act s601ED).

P2P Lending FCA Authorisation and Reporting

Regulatory Reporting: We can help you prepare and submit periodic and ad-hoc reports covering:
- UK P2P lending licensing obligations, including those FCA’s SUP (Supervision) rules.
- UK P2P lending platforms' AML/CTF obligations (including Suspicious Activity Reports (SARs) to the National Crime Agency (NCA), and other reporting obligations).
- FCA regulated P2P lending platforms' obligations under financial market regulations.
Compliance Documentation: We can help you develop and maintain the necessary documentation to meet record-keeping obligations under various laws and regulations.
Audit Readiness: We can prepare you for audits and reviews to demonstrate compliance with regulatory requirements, provisions of the FCA framework for P2P lending platforms, applicable operational standards, and more.

FCA Authorisation Solutions for the UK Authorised and Recognised Funds | Pre-licensing Support | FCA Authorisation Application Management | Post-licensing Risk and Compliance Solutions

Service Coverage