Variation Of Permissions
A Variation of Permission (or ‘VOP’) is an application to the Financial Conduct Authority (FCA) that is used to request additional permissions, the removal of certain permissions and the removal or introduction of limitations on the permissions you already hold.
Such an application may be necessary if you want to start a new line of business, start conducting a new regulated activity or add a new product or client type to your business line.
When you obtain authorisation from the FCA you are permitted to conduct certain regulatory activities under the specific permissions granted to you by the FCA.
Different permissions are necessary for different activities, for example, you cannot make introductions for customers looking to take out a mortgage if you only have permissions relating to insurance.
The process is similar to applying for authorisation however a Variation of Permissions requires updated regulatory documents such as a new Regulatory Business Plan which would outline why the firm can, and wishes to, conduct this new activity.
Why do some firms hold Limited Permissions and others don’t?
You should also be aware that different compliance documentation may be required to help ensure that you are equipped to satisfy any new requirements resulting from the change to your permissions.
Additionally, other requirements may be captured that affect the amount of information that must be provided. For example, a Limited Scope firm under the Senior Managers and Certification Regime (SM&CR) may only have one Senior Management Function holder (SMF). By adding additional permissions, the firm may no longer be a Limited Scope firm and consequently may need to seek approval for a number of its directors or other senior managers to be appointed by the FCA as SMFs under the SM&CR.
Similarly, as a result of the variation, your fees, financial category, financial resource requirement and reporting requirement may change.
You cannot start the activities that you have requested under the Variation of Permissions application until your application is approved by the FCA.
Appointed Representatives and Principal Firms
Some firms that are authorised by the FCA can enter into an agreement enabling one or more non FCA-authorised firms to conduct regulated activity without first obtaining permission from the FCA. The FCA Authorised firm in this type of relationship is known as the Principal Firm whilst the other party is known as an Appointed Representative.
The nature of these relationships means that the Principal Firm is accountable to the FCA for ensuring the Appointed Representative complies with the FCA’s rules. For that reason, it normally comes at a cost to the Appointed Representative.
Many firms start as Appointed Representatives before seeking direct authorisation from the FCA, although this is not required.
For more information on Appointed Representatives and Principal Firms please click here.
How Can MEMA support you?
MEMA has been supporting firms through the FCA compliance process since 2019. In that time, we have helped hundreds of businesses to successfully gain and retain FCA authorisation.
We have a unique blend of experience from ex-regulators, big 4 consultants and fin/regtech specialisation. Our team is highly experienced and expertly skilled. We specialise in providing our clients with solutions to often complex regulatory requirements and compliance needs.
Our unique industry insight and comfort with compliance enables our team to support you to the fullest extent possible, helping to develop your business model and compliance.
When providing our variation of permission support, we help you throughout this process by completing the online application, drafting your revised business plan and providing a suite of compliance documents to help you remain compliant after successfully varying your permissions. We’re also on hand throughout the process and afterwards to advice and support you and your firm.
Ongoing FCA Compliance
As an FCA authorised person or firm, you might need help to ensure you comply with the FCA’s rules.
We provide our clients with support they need to maintain compliance and avoid breaching the rules. Our bespoke service is individually tailored to each of our client’s requirements and objectives to help them meet in the best way possible.
Whether you need documentation to help you remain compliant, want ongoing advice or support, impartial monitoring of your activities or anything else, MEMA may be able to help.
Why Choose MEMA?
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MEMA has been supporting firms through the FCA compliance process since 2019. In that time, we have helped hundreds of businesses to successfully gain and retain FCA authorisation.
We have a unique blend of experience from ex-regulators, big 4 consultants and fin/regtech specialisation. Our team is highly experienced and expertly skilled. We specialise in providing our clients with solutions to often complex regulatory requirements and compliance needs.
Our unique industry insight and comfort with compliance enables our team to support you to the fullest extent possible, helping to develop your business model and compliance.
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Your key contacts
ADEMOLA OMOSANYA
Ademola is an accomplished consultant with over a decade of experience across regulation, banking, and consumer credit. As MEMA Consultants co-founder, he leverages extensive regulatory expertise to guide clients through critical processes and full compliance. His experience across sectors enables tailored solutions to complex business challenges. Ademola partners with clients as a strategic advisor to help futureproof their business through an in-depth understanding of the regulatory landscape.
MISAH MARAGH
Misah is a director at MEMA Consultants with over a decade of experience in financial services. Holding a legal background and postgraduate qualification, she previously worked at the Financial Conduct Authority. Misah has led compliance transformation for global consumer services organisations across Europe, the Caribbean, and Latin America. Her expertise includes implementing compliance frameworks for financial regulations, FCPA, UK Bribery Act, data privacy, and Sarbanes-Oxley. Misah is skilled at advising clients on operational and strategic projects, leveraging her in-depth knowledge of regulatory environments to deliver solutions tailored to complex business needs.
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