Compliance systems need to be set up and documented, so that applicants have adequate documentation to send with their applications. There is a limited period in which to get applications organised. The final rules are due to be announced in the Autumn of 2003, and the FSA will start to accept applications form January 2004.
Although regulation does not go live until 31 October 2004, packagers needing to be authorised were urged to submit applications as early as possible. The FSA has a six month time limit to deal with each application, so they should be submitted by the end of April 2004 to guarantee a decision by the end of October. The earlier that applications are submitted, the less likely they are to be caught up in a log jam of last minute activity in the late summer of 2004. However, the good news is that application forms are likely to be slimmed down to 20-30 pages for the basic authorisatin and the FSA is striving to make the process as simple as it can.
Stuart Aitken, SPML’s director of credit said: “It is vital for brokers to keep talking to their lenders and general insurance product providers throughout the ongoing consultations to make sure that their views are passed on to the FSA. In addition, everyone needs to start spending time now on getting compliance systems in place and on keeping complete records so that their compliance can be proved if put to the test later.”
