5 minute read

How to respond to an FCA information request

Turn the letter into a controlled response: clear answers, attributable evidence and no surprises at the deadline.

First, understand the request you actually received

Read the communication in full, including attachments, definitions, the requested period and submission instructions. An ordinary supervisory request, a formal statutory notice and an enforcement investigation are not interchangeable. Identify the basis stated in the communication and obtain legal advice where rights, privilege, compulsory powers or possible misconduct need consideration. Do not assume every request means enforcement action.

MEMA recommends a single response owner and a named reviewer, supported by the people who understand the underlying operations. Preserve the original letter and correspondence. Record the deadline, requested format, affected entities, products and systems. A short internal briefing should explain what must be answered and where a separate decision or notification may be required.

Build the response around questions, not folders

Create one matrix row for each question or distinct part of a question. Draft the answer in plain English, then link the records that support it. A large document upload is not a substitute for explaining what those records establish. Conversely, a confident narrative cannot replace evidence where the question asks for records, transactions or approval history.

Use a stable evidence identifier, the relevant page or workbook location, the source system and the applicable date. State whether a figure is a complete population, a sample or an estimate. Reconcile totals to the source and explain exclusions. If two systems disagree, show the difference and the reconciliation instead of choosing the more convenient answer.

  1. List every question and allocate a responsible contributor.
  2. Record the evidence needed and its source.
  3. Explain any gap, ambiguity or conflicting record.
  4. Review the complete answer and evidence together before submission.

Tell the FCA early if something cannot be supplied

If the request is unclear or the deadline is not achievable, contact the named FCA contact promptly. Explain the specific problem, the work already completed and a realistic alternative, including a staged delivery where suitable. Asking for more time is not the same as receiving it: keep the existing deadline in your plan until a change is confirmed.

Do not describe an unavailable historic record as supplied merely because a new check has now been performed. Explain the historic position, current protective action and any remaining investigation separately. Where a response needs correction after submission, make the correction traceable and consider the applicable notification obligations rather than silently replacing a file.

Make the final submission easy to assess

Use a short covering note stating what is included, the evidence cut-off, unresolved items and agreed next steps. Check that attachments open, workbook filters do not hide relevant rows, screenshots are legible and access permissions work for the intended recipient. Exclude unrelated personal information and preserve privileged material appropriately; do not send it casually as part of a bulk export.

Retain an exact copy of what was sent and the submission receipt. Record who approved the response and when. MEMA can support the question mapping, evidence preparation and independent challenge, while management remains responsible for the accuracy of the firm’s submission. This workflow is recommended practice, not an FCA-prescribed template or a guarantee about the supervisory outcome.

A fictional worked example

The starting point

We have uploaded the compliance folder. Everything requested should be there.

A more useful approach

Question 3 is answered in the response matrix. Evidence EV-014 shows the approved procedure; EV-015 shows its application to the stated period. The older system export is unavailable and the limitation and recovery work are explained.

The recipient can identify the answer, test its support and understand the limitation without searching an entire repository.

Useful templates

Questions on this topic

4 questions

What should we do first when the FCA requests information?

Read the whole request, establish its basis, deadline and scope, then appoint one response owner and a reviewer. Preserve the original communication and map every question to an answer and supporting evidence.

If it is a formal notice or raises privilege, misconduct or legal-rights questions, obtain appropriate legal advice. An information request is not automatically an enforcement investigation.

Can we ask the FCA for more time to respond?

You can contact the named FCA contact promptly to explain the specific difficulty, propose a realistic date and offer staged delivery where useful. Include what can be supplied by the original deadline.

Do not assume the deadline has changed because an extension was requested. Retain written confirmation of any agreed change and comply with the operative request or obtain legal advice about a formal notice.

How should we structure an FCA response?

Use a question-by-question response matrix. For each point give the answer, evidence reference, relevant period, limitation and outstanding action. Reconcile figures and distinguish complete populations from samples.

Add a short covering note and an exact attachment list. This is MEMA’s recommended working method, not a prescribed FCA form. Follow the format specified in your actual request.

What if we discover an error after submitting information to the FCA?

Assess its significance promptly and correct the position transparently through the appropriate FCA channel. Identify the original answer, the correction, why it changed and any wider impact.

Keep both versions and the approval trail. Consider applicable notification duties and legal advice; do not silently replace an attachment and assume the issue is resolved.

Official sources and further reading

Read the underlying material alongside the request or requirement that applies to your firm. MEMA's workflow suggestions are not additional regulatory rules.

How MEMA can help

We can help interpret the scope, organise evidence, test controls or deliver a defined remediation workstream. Where independent assurance is required, the scope and reviewer separation are agreed explicitly.

Discuss your firm's position