Regulatory perimeter consulting
Regulatory perimeter assessment
A consultant-led review for firms that need to understand how their actual activities, customer journey and permissions fit together before choosing a regulatory route.
From business model to documented route
We start with the operating model, customer journey, contractual roles and money flows. The analysis records what is known, what remains uncertain and which route should be tested next.
Scope
Scope the activity, product, customer journey, counterparties, money flows and jurisdictions.
Map
Map the facts against relevant regulated activities, exclusions, permissions and guidance.
Test
Test assumptions, identify missing evidence and discuss practical route options.
Record
Issue a written memo that records the analysis, limits and recommended next steps.
- What applies
- Whether your activities are regulated at all
- Where it sits in the rules
- PERG 2, FCA perimeter guidance
Who the assessment is for
Firms at the point where the perimeter question has to be answered on the facts.
New ventures
New ventures testing a regulated business model
Authorised firms
Authorised firms considering new products or permissions
Boards and investors
Boards, investors and advisers needing a documented route view
When firms commission one
The situations this review is built for.
What you will need to produce
- Activity and permissions map showing the reasoning behind each conclusion
- Written perimeter memo tailored to the evidence supplied
- Assumptions, exclusions, uncertainties and information gaps
- Route recommendation, such as authorisation, variation, appointed representative or further legal review
How MEMA helps
A perimeter question has a right answer, and the value is in reaching it with the reasoning visible so someone else can check it.
- 01
Establish what you actually do
The activities as operated, not as described in a pitch deck or a contract — including who does what, for whom, and where the money moves.
- 02
Test against the perimeter
Each activity assessed against the regulated activities, with the exclusions and exemptions considered explicitly rather than assumed away.
- 03
Mark the uncertainty
Where the position is genuinely unclear or depends on facts we were not given, that is stated. An assessment that hides its assumptions is worth nothing.
- 04
Set out the memo
A written perimeter memo with the conclusion, the reasoning behind it, and the information it relied on.
- 05
Recommend the route
Where a permission is needed, what to apply for and how — and where legal advice is the right next step rather than more consultancy, we say so.
What the assessment does not do
A perimeter analysis is only as reliable as its facts and sources. It supports a business decision, but it does not replace legal advice or bind the FCA or another regulator.
- This is not an FCA determination and does not bind the FCA or another regulator.
- The conclusion depends on the facts and documents supplied; material changes may change the analysis.
- The service is regulatory consulting, not legal advice. Legal issues may require specialist counsel.
- A route recommendation is not an approval, permission or assurance that a business may begin trading.
A focused engagement for real-world models
A decision record you can use
Built around the evidence in front of you.
- Fact-specific review
- Written memo and activity map
- Recommendation with assumptions and gaps
Start with the free perimeter self-check
Use the existing self-check for an initial indication. Move to the consultant-led assessment when your model, permissions route or evidence needs a fact-specific written review.
Open the perimeter self-check →Talk to MEMA about a regulatory perimeter assessment
Share the context, timing and outcome you need from the engagement. We will confirm whether this service is a good fit and what information would be useful before a first call.
Prefer to talk it through first? Call and you will speak to a consultant, not a switchboard.
Related guidance
Free perimeter self-check
An initial indication before the consultant-led review.
GuideFCA Handbook: PERG 2
Current FCA perimeter guidance on authorisation, regulated activities and the permission regime.
GuideFCA: How to apply
The FCA's current application guidance, including the applicant's accountability for its application and explanations.
Frequently asked questions
How is this different from the free perimeter self-check?
The free perimeter self-check is a useful starting point for an initial, general indication. This consultant-led service is a fact-specific review of your actual model, documents, permissions and intended route, with a written memo and a discussion of assumptions, exclusions and gaps.
Will the assessment confirm whether the FCA will authorise us?
No. MEMA’s assessment is a professional analysis and route recommendation, not an FCA determination. The FCA makes its own decisions based on the application, evidence and circumstances before it.
What information do you need?
Usually the proposed or current customer journey, products and services, counterparties, money flows, contractual roles, distribution model, jurisdictions, permissions and relevant existing documentation. The exact list is agreed at scoping.
Do you provide legal advice?
This service is regulatory consulting, not legal advice. Where the question turns on legal interpretation, contractual construction, litigation, privilege or another matter requiring counsel, legal advisers may need to be involved.
Related Services
View all services →Not sure whether you need permission at all?
Tell us what the business actually does and we will tell you where it sits against the perimeter — including when the answer is that you need nothing from us.
Phone: 0330 133 0811
Email: contact@memaconsultants.com