Funeral Plan Provider Application Refused By The FCA

Two days before the FCA begins its regulation of UK funeral plan providers the regulator has announced its refusal of One Life Funeral Planning Ltd’s application for authorisation.

One Life was unable to convince FCA that it could meet its regulatory standards. In its formal Decision Notice (the public notice setting out its decision) FCA explains that it had concerns that One Life could not demonstrate that it is ready, willing and organised to comply with the requirements of the FCA’s regulatory system and ultimately was unable to demonstrate that it can meet the FCA’s threshold conditions for authorisation.

Of particular interest here is the fact that FCA’s assessment of the application included interviews with individuals at the firm where two of those individuals failed to demonstrate that they had the required competence and experience to perform Senior Management functions. This resulted in FCA reaching the view that One Life did not have adequate non-financial resources to meet its requirements.

In addition, the firm had proposed the use of a customer acquisition model not compliant with the FCA’s rules. Without the use of this model it became questionable as to whether the firm would be able to sustain its business.  Finally, following a review of customer calls, the firm’s sales scripts and the financial promotions placed on the firm’s website, the FCA unearthed concerns regarding poor sales practices at One Life.

As a result of the FCA’s decision One Life now has until 31 October to transfer its customers to another provider or provide refunds to its customers.

As of 29 July all authorised funeral plan providers will need to follow new FCA rules, which include a ban on cold calling and commission paid to intermediaries, and high standards on governance and financial resilience.

Assistance with FCA Authorisations

If this article has raised any questions, or you think your firm may require assistance, please contact Jan Hagen via to book in a free consultation. Our team is on hand to not only help in the preparation of applications for direct FCA authorisation but can assist firms once the application is submitted as well.

How Complyport can help

Compliance assistance can be invaluable to a firm setting out on the road to regulation, especially against a dynamic backdrop of ever-updated expectations and requirements. Additionally, we can assist the director’s and Senior Management Functions (SMFs) within firms in prepping for a FCA interviews.

Achieving the goal of FCA authorisation is not the end of the story though– if anything it instead marks the end of the beginning.  Once authorised, firms must continue to meet the FCA’s standards and rules and achieve good outcomes.

Complyport is a market leader in FCA authorisations and have successfully assisting in over 1000 applications. Over the last 20 years, we have provided guidance and advice on permissions required, outlined the amount of regulatory capital the new firm will need and project managed the building of the application pack.

Once a firm is successfully authorised, Complyport’s expert consultants assist firms in remaining compliant with regulation as well as advise them on how to meet and adapt for upcoming regulatory change. We are currently providing regulatory support to over 600 regulated firms on an ongoing basis globally.

Click here to learn more about Complyport’s FCA authorisation support and to book a free consultation meeting.

About Complyport

Complyport is the City’s market leading consulting firm supporting the UK financial services industry for over 20 years. We specialise in providing Governance, Risk and Compliance services to support the regulated financial services industry to raise standards and thrive.

Complyport advises and assists firms to become authorised and to comply with the rules and requirements of regulators on an ongoing basis. Our vision is to be there for our clients every step of the way, helping them change, grow, and excel through expertise, insight, and innovation, and in so doing to become our clients’ most valued supplier and trusted advisor.

With presence in the UK and EU, as well as via our Associates Network, Complyport can assist firms across multiple jurisdictions.

Complyport’s multidisciplinary consultants possess deep expertise in their field, having acted in FCA skilled person reviews, as expert witnesses in legal cases and as expert investigators for firms or their legal advisers.

Day to day, we conduct audits and reviews of a firm’s products, processes, policies, and procedures to identify scope for business, to determine the impact of regulatory developments and to verify compliance with local regulations. Complyport can also assist firms by providing personnel to cover all the key compliance functions including resourcing individuals to be registered as your Compliance Oversight Function (SMF16) and/or Money-Laundering Reporting Officer (SMF17).

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