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Post-Brexit: FAQs

FCA Authorisation and Compliance for EEA Firms in the TPR

The FCA is now contacting firms who signed up to the Temporary Permissions Regime (TPR) and offering a “landing slot” to apply for full authorisation – they have a three month to submit their application, starting July 2021. Firms who miss their slot risk losing their temporary permissions completely.

In the run-up to the UK leaving the European Union, the FCA introduced the Temporary Permissions Regime (“TPR”) for EEA firms who had previously been allowed to offer their investment services in the UK under the passporting regime, without the need for FCA authorisation.

There is a short window for firms to complete this authorisation - three month slots starting in July 2021

Preparing the necessary application for authorisation or drafting a variation of permission can be a complex and onerous task. The authorisation process involves the FCA’s assessment of whether a firm, its owners and management meet specific threshold conditions across a broad range of areas, including their business model, ownership, risk control, governance arrangements, financial resources, experience, knowledge and propriety.

Our FAQ provides essential guidance for firms wishing to move to full authorisation subject to being invited by the FCA and outlines how we can support firms with this challenge, especially given the tight timeframe.