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FSA - CP13/3 - Regulatory reform: transitional provisions

We are responding only to indicate our support for the proposals as outlined in the consultation document.  We are very pleased that the proposed policy will mean that existing approved persons’ status and applications already underway will be retained and processed automatically without the need to re-apply.  The costs of a full re-application process would have been significant for all concerned, including the new regulatory bodies. Particularly significant would have been the costs to smaller, dual-regulated firms such as credit unions.

We would like to make two suggestions however in this respect:

  1. We think it would be appropriate to notify all firms directly as to where an outstanding application has been directed following “legal cutover” and likewise to directly inform all approved persons by which body their approval is now authorised.  It is important that all parties are fully aware of the status of their approvals and applications to avoid costly confusion and to ensure that consumers’ interests are not thereby undermined.
  2. We would suggest that, at the soonest possible opportunity, full confirmation of the transitional provisions for all approvals and authorisations is made available as far as is possible before “legal cutover”. While we appreciate that full certainty before this time is not possible, a statement of expected policy would alleviate the concern of some of our members who remain unsure of their position in the process of transition.

The full response is available to download on the right hand side.