As anticipated the FSA is to regulate firms in the Sale and Rent Back sector in Q2 of 2010 but firms have to submit their application and supporting information to the FSA during July 2009, the deadline for interim authorisation.
SRB firms who operate in the market today and do not have directors and managers already authorised by the FSA face a challenging process and timetable. Failure to apply to the FSA will stop anyone from carrying out SRB activity from 1 July 2009.
The FSA is to publish an application form which will show details of the applicant, the business structure, systems and controls, processes and documentation. Each director or partner has to complete an individual form which will capture detailed personal and financial information and similar rules will apply to anyone with a controlling interest of 10% or more
Richard Farr Project Director at Telos Compliance said “ The FSA’s application process is complex and particular emphasis is always placed on senior management being ‘fit and proper’ to carry out their role”. The FSA says firms must supply ‘significant additional information’ and lists 10 key documents and process statements they want to see. Farr continued “Although the FSA is providing assistance through its website, SRB firms would be wise to consider professional guidance from experts who are familiar with the FSA application process if they are to meet these tight deadlines.”
The additional documentation is requirement in free format and ranges from detailed business plans to a Treating Customers Fairly policy
