I. 2 Compliance
There are a number of decisions that a start-up broker needs to consider that will impact the firm’s compliance regime.
I.2.1 Authorisation
Financial Conduct Authority (FCA) authorisation can take time and an alternative for a business that wants to start trading right away is to become an Appointed Representative of another broker, relying on and complying with their FCA authorisation.
Direct FCA authorisation currently takes a minimum of six months – more information can be found at https://www.fca.org.uk/firms/authorisation
For companies that can be deemed to be InsurTech innovators. consideration can be given to applying via the FCA Regulatory Sandbox route for a speedier process.
I.2.2 Competent Employees: Senior Managers and Certification Regime (SM&CR)
The Governance Section of the Good Practice Guide Section B3. Compliance provides information about the requirements of SM&CR and further guidance is available in a special edition of Compliance Rules which can be accessed here . https://view.publitas.com/biba/compliance-rules-quarter-2-2019/page/1
I.2.3 Capital Requirements
The FCA has capital requirements that set how much capital a firm must hold depending on the nature of its authorisation (direct/authorised representative etc.). More information can be found at https://www.fca.org.uk/firms/capital-requirements-permissions