Senior Manager Applications: easier to apply but harder to get approved?
Over the last month, FCA have published information on changes to application forms which they say will make it quicker and easier for firms to apply for authorisation. The Form A, used for Senior Management and Controlled Function applications, is being updated first. But don’t confuse a more straightforward application form with an easier route to being FCA approved, in fact in our experience it is quite the opposite.
In many cases, what would have been considered a strong candidate for a Senior Management position 12-18 months ago is being put to the test with FCA spending more time scrutinising applications and using interviews more readily to assess candidates in closer detail. The advantages are obvious - a robust assessment is essential to ensure only those individuals with the knowledge, competence, influence and expertise occupy key positions in financial services. However, firms who underestimate the scrutiny applied during the process and put forward inappropriate candidates or submit sub-par applications, could find themselves being invited to withdraw applications and scrambling for alternatives. We recommend that all firms ensure due diligence is completed thoroughly before submitting applications and ensure answers to questions are full and detailed enough to avoid the delay of additional questions from FCA Case Officers.
If you need assistance, we are happy to help! Our team includes ex-regulators experienced with interviewing candidates and can help with reviewing applications before they are submitted, assisting with responses and preparing for interviews.
But for those firms who might be required to use the new Form A, how is it changing?
The new form will initially only be available to firms that are already authorised and who are applying for new Senior Manager Functions via the Connect system. It will be rolled out to other types of related applications such as New Authorisation and Variation of Permission once testing is complete. The old Form A is still available but will be removed once the rollout is complete.
The FCA have taken on board industry feedback when refining the new form and hope it will make it easier for firms to apply. Some of the changes they have made are:
a helpful checklist of information you need to complete your application before you start
less duplication in the employment history section – if you're a solo-regulated firm, you can input 10 years of employment history instead of uploading a CV
improved data validation and pre-population to help you fill in your application quicker
the Statement of Responsibilities (SOR) is integrated into the Form A, so you don't need to complete a second application for this
removal of the 'Send later' function
improved help and guidance throughout
easier navigation and an improved layout
Firms who regularly use Form As will receive an email about the changes but if you want to use the new form and provide feedback, you can do this by emailing gateway.userresearch@fca.org.uk.
There is further information on the FCA website along with a video about the changes. You may also want to read a recent blog from Emily Shepperd (Chief Operating Officer and Executive Director, Authorisations) on the topic.