As we approach February 2024, we would like to take this moment to remind you that the Financial Promotions Gateway regime Financial Promotions Gateway regime will start to be applied by the FCA from the 7th February 2024. Therefore if you currently approve financial promotions for unauthorised persons then you must apply to the FCA to become a Section 21 approver before 6th February 2024. If this deadline is not met then you must cease approving financial promotions for unauthorised persons until approval is granted.
Securing approval as a Section 21 approver involves submitting a Variation of Permission (VoP) through the Connect platform, accompanied by a completed financial promotions form. This form, situated at the bottom of the VoP draft under ‘related returns,’ is instrumental in evaluating the impact of the added responsibility on the applicant’s business model, capital requirements, IT systems, and indemnity insurance.
The main element of the application, the Financial Promotions form, looks at how the added responsibility of being a Section 21 approver will affect your firm. The main elements explored within the form are as follows:
- Your firm’s current Financial Promotions Policy;
- How your firm will monitor any firm for whom you approve financial promotions;
- Key information that will be recorded and fed to the Board;
- How many financial promotions you have approved for unauthorised firms in the last 3, 6 and 12 months; and
- How much will be charged to approve financial promotions for other firms and expected revenue generation from such a service.
It is important to note that, upon obtaining approval to oversee financial promotions, your firm will be obligated to submit a REP024 – Financial Promotions, Aggregated Biannual report through RegData every 6-months.
How Can Complyport Help?
If you require assistance with the development and/or submission of a Variation of Permission and accompanying financial promotions form then please do let us know.
If you have any questions or anything else we can assist with in the interim, Contact Thomas Salmon, Regulatory Business Solutions, via email at thomas.salmon@complyport.co.uk
About Complyport
Complyport is a market-leading consulting firm supporting the UK financial services industry for over 22 years. We specialise in providing Governance, Risk and Compliance services to support the regulated financial services industry to raise standards and thrive.
Complyport can assist with the preparation of a GAP analysis and impact assessment on the investment firm’s capital adequacy and risk management framework of the Company under the regulatory framework.
We specialise in supporting the UK financial services industry with compliance guidance, advice and best practice.
- Financial Promotions guidance, support, and management software solutions
- Skilled Person Reviews and Regulatory Investigation
- Prudential support, IFPR, ICARA and financial resilience advice
- Financial Crime support and Forensics
- Compliance managed services and resourcing compliance personnel
- Consumer Duty implementation advice
- Operational resilience & Cybersecurity advice
- CASS advice and protections of client assets
- Comprehensive compliance work-flow management software
Contact Thomas Salmon in our Regulatory Solutions team via email at: thomas.salmon@complyport.co.uk to book a free consultation.
