Policy & Procedures

We will draft or review the following policy and procedures for your financial services business:

Anti-money laundering (AML) & Countering the Financing of Terrorism (CFT) policy and procedures;
Fitness & Probity policy and procedures;
Minimum Competency Code (MCC) policy and procedures;
Complaints policy and procedures;
Conflicts of Interest policy and procedures.
Staff Training Legal Compliance

Frequently Asked Questions (FAQs)

What are the key stages in the Authorisation Process?

The key stages are as follows:
1. The applicant completes and submits the application form together with supporting documentation;
2. The Central Bank acknowledges receipt of the application form and supporting documentation;
3. The Central Bank reviews the application submission to determine if the applicant has provided key information and documentation;
4. The applicant is provided with log-on details for the Central Bank’s Online Reporting System (ONR);
5. The applicant is required to complete and submit an Individual Questionnaire (IQ) via the Central Bank’s ONR;
6. If the applicant is a sole trader or a director of a limited company, he/she will be required to navigate through the online e-Vetting process;
7. The Central Bank determines whether the applicant has provided completed IQs, Vetting Invitation Forms and Vetting Application Forms as well as acceptable certified proof of identity;
8. The application progresses to the assessment phase when the Central Bank determines that all key information and documentation has been provided;
9. The Central Bank assesses the applicant’s submission and may issue detailed comments and/or seek additional information;
10. The applicant addresses the comments issued by the Central Bank and or provides the Central Bank with the requested information;
11. The Central Bank will notify the applicant of its decision in relation to the application submission.

How long does the application process take?

Each application to the Central Bank is assessed on its own merits. In order to give you a projected timeline to authorisation, we encourage you to contact us at the earliest possible stage to arrange a free consultation. This will enable us to discuss your business model, the types of authorisation(s) you are looking to apply for and take you through each step of the authorisation process.

What type of authorisation(s) do I need to apply for?

This is an important question that you should be in a position to answer prior to making an application for authorisation to the Central Bank. Depending on the nature of the products or services you intend to provide, you will be required to apply for some or all of the authorisations outlined below:-

European Communities (insurance Distribution) Regulations 2018;
Investment Intermediaries Act 1995;
European Union (Consumer Mortgage Credit Agreements) Regulations 2016;
Consumer Credit Act 1995.

Do I need a qualification to become a Broker?

Yes, you are required to hold a qualification relevant to the products or services you intend to provide to consumers. (For example, you are required to hold the QFA designation when you provide advice to customers.) However, there are exceptions outlined in the Minimum Competency Code that enable you, in certain circumstances, to become a broker if you have not yet received a relevant qualification.

What is a PCF?

A person performing a Pre-Approval Controlled Function (‘PCF’) must be pre-approved by the Central Bank. This means that you cannot commence working in a PCF designated role until you receive formal written approval from the regulator.

For example, if you are applying to be a sole trader you will apply for the PCF-10 (Sole Trader) role. Similarly, if you are applying to be a director of a limited company you will apply for the PCF-1 (Executive Director) designation. A full list of PCF roles are outlined on the Central Bank’s website.

What is an Individual Questionnaire?

An Individual Questionnaire (IQ) is a 12 page document that all PCF’s are required to complete when submitting an application for authorisation to the Central Bank. It requests applicants to provide:

personal information;
information in relation to professional experience;
information in relation to reputation and character;
information in relation to current and previous regulatory approvals;
information in relation to shareholdings/business interests;
information in relation to positions held as director, chair or manager in any other entity.