Firms Should Ensure That Permissions Are Reviewed Regularly

The FCA’s threshold condition “use it or lose it” project is focusing on firms that may not be using their permissions. As part of this process, the FCA is requesting data under their information gathering powers concerning firms’ business models and group structures. The request can also include details on types of clients, professional indemnity insurance policies, internal capital adequacy assessment processes (ICAAPs) and wind-down plans.

The FCA has previously highlighted that firms should keep their permissions under review. If permissions have not been used for 12 months, firms should consider removing those permissions.

If you receive a request for information from the FCA, we recommend that you reach out to your usual contact at Kroll who will be able to assist you.