Applications for Part IV permission and VOPs

The published statutory service standard for completing "clean" applications and VOPS is 6 months and 12 months for incomplete applications.

Many Firms will have experienced delays with their applications and the FSA have taken action to improve matters. Back in November 2009 some 300 applications took in excess of 5 weeks to be assigned to a Case Officer. this figure has since reduced to some 100.

As each Case Officer is likely to have up to 20 ongoing applications it is particularly unhelpful if applicants or their advisers keep hassling Case Officers on a daily basis.

The FSA have recruited additional staff to handle applications and further staff will be joining the Permissions, Decisions and Regulatory Reporting Team over the next few weeks.

Applicants are under much closer scrutiny than previously - the onus is on the applicant Firm to demonstrate competence and does the application stack up?

Does the business plan support the planned business model?

Are the Owners / Managers of the business competent to run a Regulated Firm?

Have there been any past issues involving the Directors - previous businesses going into Administration etc?

Where does the Capital for the business come from?

Do the staff dealing with customers have the necessary skills, knowledge and qualifications to advise clients?

What IT systems will be adopted?

Is there a "believability factor" with the application?


The FSA have noted that most applicants now use the services of professional advisors - Accountants or Compliance Consultants. Whilst this is helpful, the FSA still require the main contact for the application to come from within the business.

It was a breath of fresh air for the FSA to admit their shortcomings - and demonstrate the steps that they had taken to speed up the process for dealing with applications.


Those Firms that are currently Authorised should review their current permissions and where necessary apply to deregister any that are no longer required. Permissions as at the end of March determine the fee blocks applicable for the following 12 months. The FSCS fees can be onerous and there seems little point paying unnecessary fees. Some 30% of VoPs are received during February and March.

Time to review your permissions.