After a brief fanfare near the end of last month, the UK's Financial Conduct Authority has begun to devote more man-hours and software to the job of authorising asset management start-ups.

Compliance Matters has already covered the likely features of the 'hub' here. The FCA has now, however, publicised the steps that start-ups are going to have to take before being allowed to do regulated business. These, directed at hopeful firms, are as follows.

• What do you offer? Decide on: products, services, customers, geography etc.
• Are you within the FCA's 'regulatory perimeter'? (No need to go further if the answer is no.)
• Look at the FCA's Regulated Activities Order and decide on your 'scope of permission' (the FCA often uses phrases of this kind, although - as here - it is not very good at explaining them).
• Decide whether you fall under any EU directive.
• Read the Financial Services and Markets Act (under which the FCA is founded) and EU directives to find out what 'approvals' (in the FCA world, 'approval' can be plural) you need.
• Decide what resources you need, in terms of people, finance, systems, policies etc.
• Create a Connect account.
• Build your application pack. (The phrase 'building a pack' is not defined.) Download forms from Connect (the FCA's online system that you can use to apply for various things and submit information) and from the FCA website.
• Create any supplementary documents.
• Do you need to meet some regulators before you apply? If so, contact the FCA.
• Check to see how much you need to pay in application fees.
• Submit your application (this might have something to do with the 'built pack') along with your fee, over Connect.
• The FCA sends you an email of acknowledgement.
• It logs your application, creates an internal case and sends it to the relevant team(s).
• Your case officer will get in touch within two working days.
• He then reviews your application for the first - but not the only - time.
• He will contact you with queries and tell you whether your application is complete. (You ought to respond as soon and as honestly as possible.)
• He will keep you abreast of developments. While he is on your case, you can email or telephone him at any time.
• If he can (and this is a big 'if') he will indicate whether your application is progressing well or badly (see below for what happens if things are progressing towards a refusal).
• If things are progressing towards approval, the case officer will give you a list of 'subject to' items, i.e. the things you have to do to obtain approval. Here the FCA says that the case officer 'agrees' the list and that it ought to give the firm some 'flexibility,' but this is all it says.
• Your application is approved and you receive an 'authorisation letter' by email.
• You can now start to do business. You will be regulated under the FCA's supervisory regime (either fixed or flexible).
• The FCA will call you to welcome you and say what it expects from you as an 'supervised firm.' (The actual FCA phrase is 'authorised firm.')
• If you need to, you must now apply in writing for 'passporting,' marketing etc.
• You now need to sign up online to Connect, Gabriel (another FCA reporting link), the fees portal (the FCA runs along the lines of a compulsory guild with Government appointees in control; perhaps because of this it refer to the levies it charges its firms as fees) etc.
• If you need support, contact the FCA's Firm Contact Centre.
• Submit relevant returns as per your Gabriel schedule.

If the application is progressing towards a refusal

If the case officer says that your case is progressing towards a refusal (in which case he will explain his worries to you) but you do not want to withdraw, there are several steps that might follow.

• He will prepare a 'minded to' letter that contains his concerns.
• He will present a 'refusal recommendation' to an internal committee (the  Regulatory Transactions Committee or RTC).
• If the RTC upholds this recommendation, the FCA will issue you with a warning notice.
• The FCA will then present the recommendation to another committee of internal and external members (the Regulatory Decisions Comittee).
• At the RDC meeting, you will be allowed to present your case (in writing, if you so choose) to the committee.
• If the RDC upholds the recommendation, the FCA will issue a decision notice to you.
• You can then appeal against the decision to a tribunal.
• If you do not appeal in time or if the tribunal also upholds the recommendation, the FCA will issue a final decision notice.
• Ever since 2010, the FCA has published all final notices on its website, so your failure will be a very public one.