Navigating a permissions lapse with a clean re-authorisation strategy

The challenge

The firm faced a lapse in its FCA permissions and an in-flight application that was no longer the right route — risking an adverse outcome on its regulatory record if pushed to determination.

Regulatory context

FCA permissions, the very different consequences of an application refusal versus a withdrawal, and re-authorisation under a restructured legal entity.

What MEMA did

• ✓Assessed the application against the FCA's position and the firm's restructuring plans
• ✓Advised on the strategic decision to withdraw rather than risk an adverse determination
• ✓Managed the FCA engagement and timelines through the withdrawal ahead of the deadline
• ✓Mapped a clean re-authorisation path under the correct entity for when the firm is ready

Timeline

Application withdrawn on MEMA's advice ahead of the FCA deadline; re-authorisation route set.

Outcome

Protected the firm's regulatory record and set up a clean re-authorisation for when the time is right.