When should brokers complete the FSA's application form? This appears to be a simple question, but, as with all things regulatory, the answer is never quite that straightforward.
The FSA has consistently urged brokers to get their applications in early to ensure that the authorisation decision can be made before January 2005. Yet, as is apparent from Sarah Wilson's exclusive interview with Insurance Times, it could be advantageous to wait before completing the form.
Wilson says that a firm will be judged on the basis of the confidence that the FSA has in it becoming compliant by 2005. If it appears that a firm has done more to achieve compliance then the FSA will have more confidence in it. The inference is that if a firm is further down the road to compliance it is more likely to be authorised.
So brokers shouldn't just rush into completing the form as soon as possible. Better to develop a proper, well thought-out compliance plan and set about implementing it.
Of course, they must not forget the 14 July cut-off date, the last date by which the FSA can guarantee to process applications in time for January 2005. And this date refers only to perfect applications. For those with errors or omissions there needs to be additional time to correct the imperfections; so the earlier the application is sent in the better.
Brokers must therefore bear in mind another of Wilson's key messages: to act now and finalise compliance plans.