MEMA Guides / FCA interviews
Preparing for an FCA interview: a practical guide
What an FCA case-officer call is testing, the questions that come up, how to make your documents agree, and a four-week plan to prepare.
- Audio + videothe FCA says it might record a call, capturing the audio and visualsSource
- Youthe FCA expects to deal directly with you in meetings, not your adviser or compliance consultantSource
- Small panelfor senior manager interviews the FCA keeps the panel as small as possible, and may invite the candidate backSource
The guide in 30 seconds
Practical guidance- 01Know your own documentsMost damage comes from a form, a plan and a policy that say different things. Reconcile them before the call.
- 02Answer for yourself, in hours and namesSpecific, owned answers beat polished general ones. Say what you do, how often, and who decides.
- 03Rehearse aloud, then stopTwo mock interviews with someone who has not read the plan will find more gaps than another read-through.
Explore the chapters
Read them in order, or jump to the one you need.
01Why the FCA interviews, and why "not formal" still countsA form shows a CV. It cannot show whether the people running the firm understand the business. The call fills that gap, and what you say goes into the assessment.
02What to expect on the dayKnow the shape of the call, who may be listening and what to do when you do not know the answer. Most of the day is decided by how you have prepared.
03The five themes, the questions and what a strong answer coversAcross the interviews we have seen, the questions fall into five themes. For each, here is what the FCA is testing, a question bank and how a weak answer differs from a strong one.
04Reconcile your documents before the callThe most damaging problems are inconsistencies: a form that says one thing and a plan that says another. A line-by-line reconciliation finds them while you can still fix them.
05Common traps, outcomes and what to ask the case officerAn interview rarely ends with a decision on the day. Know the traps that draw follow-up, the outcomes that are possible and the questions worth asking before you hang up.
06Mock interviews and a four-week preparation planRehearsing aloud, with someone who has not read the plan, finds more gaps than rereading ever will. Use this plan to fit preparation into four weeks.
Chapter 01 · The starting point
Why the FCA interviews, and why "not formal" still counts
A form shows a CV. It cannot show whether the people running the firm understand the business. The call fills that gap, and what you say goes into the assessment.
An FCA case-officer call or interview is a conversation between the FCA and the people who will run the firm, usually the directors, the Compliance Officer and the MLRO. It can happen during an authorisation, a registration or an approval of a senior manager. Its job is to test whether those individuals understand their regulatory obligations and can run the business as described in the application. This guide is about doing that well. Our Insights article "FCA authorisation interviews: what the FCA asks and how to prepare" gives the short version, and this guide adds worked examples, answer frameworks and a plan.
For payment institutions the legal test sits in the Payment Services Regulations 2017 (PSRs). For an authorised payment institution, regulation 6(7)(b) requires the applicant to satisfy the FCA that the directors and the people responsible for management are "of good repute and possess appropriate knowledge and experience to provide payment services". Regulation 14(7) applies the same test to a small payment institution, and the Electronic Money Regulations 2011 have an equivalent in regulation 6(6)(b).
They'll usually have follow-up questions and may ask for further documentation or want to hold a call or meet with you.
The FCA also has the power to ask. For a small payment institution, regulation 13(4) lets it require "such further information as it reasonably considers necessary to enable it to determine the application". For senior management function (SMF) candidates, the FCA says it may invite a candidate to interview, keeps the panel "as small as possible" and "may invite the candidate back for another interview".
Chapter 02 · Format and ground rules
What to expect on the day
Know the shape of the call, who may be listening and what to do when you do not know the answer. Most of the day is decided by how you have prepared.
Expect a call of about an hour with the case officer and often a colleague. The FCA's authorisation page says: "If we hold a call with you, we might record it (capturing the audio and visuals) to help us assess your application." In the interview we have seen, the case officer opened with a warning that what was said would be recorded and must be accurate, and said they might re-watch the recording afterwards. The same interview had cameras on and no reading from a script or notes.
The shape of a typical call (as seen in a recent payment institution interview)
- OpeningThe FCA introduces itself and its roleStates the purpose, covers recording and accuracy, and confirms who is on the call.
- EarlyCareer, roles and timeEach individual is asked for their background and current commitments.
- MiddleBusiness, structure and governanceCustomer journey, group structure, reporting lines and conflicts.
- MiddleControlsRisk assessment, onboarding, monitoring, safeguarding and reporting.
- CloseNext stepsDocuments to follow, a possible follow-up call, and anything the FCA will confirm by email.
Who should be ready for what
You own the business model and the plan.
- Explain the customer journey and how money moves, from receipt to payout
- State your other roles and your weekly hours in one clear table
- Say who decides when commercial and compliance interests differ
You describe how the firm stays within the rules.
- Know every policy the firm holds and which regulation it answers
- Explain monitoring, testing and what gets reported to the board
- Be ready to say what is not yet in place and when it will be
You run the anti-money laundering arrangements.
- Explain how the risk assessment was built and approved
- Walk through onboarding, including a check that comes back amber or red
- Describe how you would handle a suspicion, and your independence
You may be asked the same question to see if answers align.
- Know the whole plan, not only your own area
- Do not defer every question to a colleague
- Say "I do" for what you do, and explain how you oversee what you delegate
Three ground rules for the call
Speak for yourself
The FCA says it expects to deal directly with you in correspondence and meetings, "not your adviser or compliance consultant". Advisers help you prepare. They cannot answer for you, so check with the case officer before anyone else attends.
Do not guess
If you do not know, say so and say how you will find out and by when. An inaccurate answer is worse than an honest gap, because it is on the record and may be replayed.
Ask what the call will cover
For SMF approvals the FCA says "We will tell you in advance what areas we wish to explore at the interview." For other applications, ask the case officer for the topics and who will attend.
Good and poor practice on the day
Poor practice
- Reading answers from a script or screen when the FCA has asked for none
- Letting one director answer everything while the others stay silent
- Rounding off a number you are not sure of
- Saying a control exists when it is still being built
- Arguing with a question rather than answering it
Good practice
- Answering in your own words, with a short example
- Each person covering their own area and knowing the whole plan
- Saying "I will confirm that after the call" and then doing it
- Separating what is in place today from what will be in place before trading
- Asking for the question to be repeated if it is unclear
Chapter 03 · Questions and answers
The five themes, the questions and what a strong answer covers
Across the interviews we have seen, the questions fall into five themes. For each, here is what the FCA is testing, a question bank and how a weak answer differs from a strong one.
The questions below are drawn from a recent payment institution interview and from preparation work we have done for firms. They are not a script and no two calls are the same. Use them to find the answers you cannot yet give.
| Theme | What the FCA is testing | Evidence to have ready |
|---|---|---|
| Career and capacity | Relevant experience, and whether there is enough time for the role | CV with dates, list of other roles, weekly time split |
| Group structure and agents | Why this entity applies, who controls what, and how conflicts are managed | Structure chart, agent agreement, conflicts policy |
| Governance and independence | Whether control functions can act independently of owners | Shareholding, voting rights, board terms of reference, escalation routes |
| Safeguarding and regulatory status | Whether the form and the business plan agree on what the firm does | One reconciled description of permissions and the funds flow |
| AML and financial crime | Whether the risk assessment, onboarding and escalation work in practice | Risk assessment, onboarding flow, tool list, escalation log |
Walk through the five themes
Stage 1 of 5
1. Career
Expect to be asked for a high-level overview of your career, whether you have held contracting roles, your current positions and how your time splits between firms.
- Give your career in two minutes, dated
- State weekly hours for every role
- Name any role shown on a professional register
Stage 2 of 5
2. Group
If a group technology company sits behind the firm, the FCA will ask why the regulated entity applies rather than the group company, and how the principal and agent relationship came about.
- Draw the structure and explain every line
- List each conflict and the person who decides
- Know what a limit such as a single agent would mean for you
Stage 3 of 5
3. Governance
Who sits on the board, how often it meets, and what happens if the MLRO and the board disagree. Shareholding and voting rights matter here.
- State voting rights plainly
- Describe the MLRO's direct line to the board
- Give an example of compliance winning against revenue
Stage 4 of 5
4. Safeguarding
Which permissions are you applying for, and does every document describe the same ones? Walk through how customer money moves from receipt to payout.
- Reconcile the form, plan and policies
- Walk the funds flow aloud
- Be able to say which status you have chosen and why
Stage 5 of 5
5. AML
How the business-wide risk assessment was put together, how a customer is onboarded, what happens when checks come back amber or red, and whether you have ever completed a suspicious activity report (SAR).
- Trace who wrote and approved the risk assessment
- Walk one amber and one red case
- Be honest about SAR experience
Questions the FCA may ask
- Give a high-level overview of your career. Have you held any contracting positions?
- How is your time split between firms? If you split your time, what does that mean in hours a week?
- Why is this entity applying rather than the group technology company?
- What conflicts of interest exist between the firms, and how are they managed?
- Who sits on the board, how often does it meet, and who takes which decision?
- If the MLRO and the Compliance Officer each hold half the votes, how will the MLRO's decisions be impartial and independent?
- Walk through how customer money moves, from receipt to payout.
- Walk us through how the business-wide risk assessment was put together and approved.
- How do you onboard a customer? If checks come back amber or red, what happens and who signs it off?
- Which third-party systems do you use for screening, ID verification and customer records?
- Have you ever completed a suspicious activity report?
Worked example, capacity: "How much time will you give this role?"
Weak answer
- "About 40 per cent of my time, give or take."
- "It depends on how the business goes."
- No mention of the other roles or when they peak
- No cover named for absence
Strong answer
- "Two days a week here, 16 hours, fixed on Tuesday and Thursday. My other role takes two days and I have 10 hours spare."
- A weekly calendar showing the busiest period, month end, and what moves
- Names the deputy who covers when absent
- Says how hours rise as volumes rise, and what triggers the review
Worked example, independence: "You hold half the votes. How is the MLRO independent?"
Weak answer
- "We trust each other and have never disagreed."
- "I would just talk to my co-director."
- Treats independence as a personality issue, not a structure
- No example of an inconvenient decision
Strong answer
- Direct line to the board, with a written right to escalate to the FCA
- A rule that decisions on high-risk customers cannot be reversed by owners
- No commercial target attached to the MLRO's pay
- An example of declining a profitable customer, and what it cost
Chapter 04 · The biggest avoidable risk
Reconcile your documents before the call
The most damaging problems are inconsistencies: a form that says one thing and a plan that says another. A line-by-line reconciliation finds them while you can still fix them.
A form can say the firm will not safeguard customer money while the business plan describes safeguarding accounts and daily reconciliations. When a case officer has read both, the question "which is true?" is certain. Regulation 23 of the PSRs places the safeguarding duty on "an authorised payment institution", and Schedule 2 asks for a description of safeguarding measures "where regulation 23 (safeguarding requirements) applies". Whichever status you choose, every document must say the same thing.
| Fact to reconcile | Where it appears | What to check |
|---|---|---|
| Permissions applied for | Form, plan, policies, website | Same list, same wording, same status everywhere |
| Safeguarding approach | Form, plan, funds-flow, policy | Either all say funds are safeguarded or none do, with the reason |
| Who the directors and controllers are | Form, structure chart, plan | Names, roles, shareholdings and dates agree |
| Hours and other roles | Individual forms, CVs, plan | Same figures for each person, with overlaps explained |
| Agents and outsourcing | Form, plan, agreements, conflicts policy | Every agent and outsourced function appears in all four |
| Customer types and countries | Plan, risk assessment, onboarding policy | Same segments, and risk ratings that follow from them |
| Staff numbers and roles | Plan, organisation chart, forecasts | Headcount, contract type and location match the cost lines |
| Volumes and forecasts | Plan, financials, resourcing plan | Growth assumptions drive the staffing and control plans |
How to run the reconciliation
- Print or export every document as filed: form, plan, policies, forecasts and any later correspondence
- Highlight every statement of fact, such as numbers, names, permissions and dates
- List each fact on one page and tick where each document agrees
- Mark every difference and decide which version is correct
- Correct the document that is wrong, and tell the FCA through your case officer where a filed document changes
- Have a second person who did not write the plan read the grid
- Agree a one-page fact sheet that every individual on the call has read
Self-check: are your documents ready for the call?
Tick each area your plan already covers. Your ticks stay in this browser only.
Chapter 05 · After the questions
Common traps, outcomes and what to ask the case officer
An interview rarely ends with a decision on the day. Know the traps that draw follow-up, the outcomes that are possible and the questions worth asking before you hang up.
The FCA's fitness and propriety guidance for SMF candidates asks "whether the person has adequate time to perform the controlled function and meet the responsibilities associated with that function" (FIT 2.2.1G). The same question is asked of payment and e-money individuals. On governance, regulation 6(6)(a) of the PSRs requires an authorised payment institution to have "robust governance arrangements... including a clear organisational structure with well-defined, transparent and consistent lines of responsibility". Both give the case officer a basis for follow-up when your answers are vague.
What the end of a call can look like (from the interview we have seen)
- On the callGaps noted, no decisionThe case officer said many gaps had been filled and that the recording would be re-watched.
- Days afterFurther documents requestedFor example an agent onboarding manual or a training manual.
- By emailA proposed voluntary requirement (VREQ) explainedWording to read closely before agreeing.
- LaterA follow-up meeting scheduledA second chance to close the remaining points.
| Route | What can happen | What it means for you |
|---|---|---|
| Authorisation or registration | More documents, a follow-up call or meeting | Answer in writing, keep a log of what you promised |
| Voluntary requirement | "You may apply for voluntary requirements to be added to your permissions" | A limit that suits an early-stage firm, such as capping customer numbers |
| Restrictions while testing | "Restrictions e.g. on the number of customers the firm can onboard" | Agree what must be shown for the limit to be lifted |
| Withdrawal | The FCA may ask you to withdraw and reapply after substantive changes | Avoid large late changes to the plan |
| SMF approval | Approval, conditional or time-limited approval, or refusal | Read any condition and its end date closely |
Questions to ask the case officer
- Which topics will the call cover, and who will attend from the FCA?
- Who on our side should attend, and can an adviser join to listen?
- Will the call be recorded, and may we have a copy of anything recorded?
- Is there a document you would like to see before the call?
- What happens next, and when should we expect to hear from you?
- If a voluntary requirement is proposed, how will we see the wording and how long do we have to respond?
In the 24 hours after the call
Write down what you promised
List every document, answer or follow-up you said you would send, with a date. The case officer will have the recording; you should have the list.
Correct anything you got wrong
If you realise a figure or statement was inaccurate, say so in writing straight away rather than waiting to be asked.
Compare notes, then send
Each person writes what they remember being asked, so differences show where answers did not align. Reply through your case officer with what was promised and file a copy.
Chapter 06 · Putting it together
Mock interviews and a four-week preparation plan
Rehearsing aloud, with someone who has not read the plan, finds more gaps than rereading ever will. Use this plan to fit preparation into four weeks.
The documents come first. Preparation that starts with a mock interview and no reconciled documents rehearses the wrong answers. Once the facts are fixed, move to speaking them aloud. The plan below is illustrative and can be compressed into two weeks for a short notice call: run the same tasks with fewer days between them.
Illustrative example Not FCA figures. Use your own.
How to run a mock interview
Pick an interviewer who has not read the plan
A colleague, an adviser or someone from another firm. They ask what a reader of the form would ask, which is closer to the FCA than a colleague who knows the answers.
Recreate the conditions
Same video platform, camera on, no script or notes, about an hour, each person asked separately and then together.
Ask each person the same question
Use five or six questions from the bank and ask them of every individual. Mark where answers differ.
Record and listen back
Hearing yourself shows hedging, long answers and the point at which you stop being specific.
Score the answers
For each answer mark specific, consistent, owned and honest about limits. Anything below a clear yes goes on the fix list.
Fix, then repeat
Fix the documents or the answer, and repeat the questions that failed. Stop when answers are steady, not when they are polished.
| Feature | What it looks like | A weak sign |
|---|---|---|
| Specific | "We review the risk assessment every six months and the MLRO presents changes to the board" | "We review it regularly" |
| Consistent | Matches the form, the plan, the policies and the other director | Differs from a document or a colleague |
| Owned | "I do", with how oversight works for anything delegated | "The team does" |
| Honest about limits | Says what cannot yet be done and what will change before trading | Claims a control that is still being built |
The night before
- Read the one-page fact sheet, not the whole plan
- Check the video link, camera and microphone, and join a few minutes early
- Have the list of questions for the FCA and a note for any promised follow-up
- Agree who answers what, knowing everyone can cover the whole plan
- Do not rewrite anything. Rest.
Where this comes from
Sources
Every number and rule in this guide comes from these pages. Check them before you rely on anything, as rules change.
- FCA: Apply for authorisation
- FCA: How we assess SMF candidates
- Payment Services Regulations 2017, regulation 6
- Payment Services Regulations 2017, regulation 13
- Payment Services Regulations 2017, regulation 14
- Payment Services Regulations 2017, regulation 23
- Payment Services Regulations 2017, Schedule 2
- Electronic Money Regulations 2011, regulation 6
- FCA Handbook FIT 2.2: Fitness and propriety, honesty, integrity and reputation
- FCA: Senior Managers and Certification Regime
- FCA: Notify changes to individuals in a PI or EMI
- Money Laundering Regulations 2017, regulation 18
- FCA Handbook SYSC 6.3: Financial crime
- FCA Handbook FCG 3.2: Money laundering and terrorist financing, governance and risk assessment
This guide is general information, not legal or regulatory advice. Rules and FCA expectations change; check the sources and take advice on your firm's circumstances.