Regulatory perimeter assessment for real-world models
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.
- Fact-specific review
- Written memo and activity map
- Recommendation with assumptions and gaps
Built around the evidence in front of you
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.
Who this is for
- New ventures testing a regulated business model
- Authorised firms considering new products or permissions
- Boards, investors and advisers needing a documented route view
Typical use cases
- Pre-authorisation and variation of permission planning
- Product, channel, provider or distribution changes
- Reviewing possible perimeter risk before launch or remediation
From business model to documented route
- 01Scope the activity, product, customer journey, counterparties, money flows and jurisdictions
- 02Map the facts against relevant regulated activities, exclusions, permissions and guidance
- 03Test assumptions, identify missing evidence and discuss practical route options
- 04Issue a written memo that records the analysis, limits and recommended next steps
A decision record you can use
- 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
Evidence-led, not outcome-led
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.
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.
Check the current FCA position
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.
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.