WB
Wholesale brokers and advisers
Firms recommending investments, arranging transactions or executing deals for professional clients and eligible counterparties.
UK FCA AUTHORISATION SUPPORT
UK FCA Authorisation Support for Wholesale Markets
Permissions, regulatory business plans, governance, prudential readiness and application support
We support wholesale market firms in defining the correct regulatory perimeter, selecting permissions that match the proposed business model, preparing the evidence expected in an FCA application and building a practical compliance framework for launch.
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WHO THIS SERVICE IS FOR
Wholesale firms with different permissions, risks and evidence requirements
Wholesale markets authorisation is not a single standard licence. The required permissions, forms, financial resources and control framework depend on what the firm will actually do, for whom, through which legal entity and with whose money or assets.
PTF
Principal trading and market-making firms
Businesses trading using their own capital, including firms that may also arrange transactions or deal as agent.
IM
Investment managers
Portfolio managers and related wholesale investment businesses requiring permissions aligned with their mandate and client structure.
MTF
MTF and OTF operators
Trading venue operators that need specific permissions, rulebooks, access arrangements, surveillance and market infrastructure controls.
CF
Corporate finance firms
Advisers supporting capital raising, admissions to trading, private placements, mergers, acquisitions and other corporate transactions.
CASS
Custodians and client-asset firms
Businesses safeguarding, administering or arranging custody of investments, with client asset and third-party oversight considerations.
INT
International firms entering the UK
Overseas groups assessing UK authorisation, governance, risk mitigation, local presence and operational substance.
VOP
Existing firms expanding permissions
Authorised firms preparing a variation of permission, a material business-model change or entry into new wholesale activities.
REGULATORY ARCHITECTURE
Define the perimeter before preparing the application
A credible application starts with a precise description of the proposed activity. Permissions must correspond to the firm's contracts, order flow, decision-making role, execution model, asset types, client types, revenue sources and operational responsibilities.
01
Business model and perimeter analysis
We map the full operating chain: onboarding, advice, arranging, order handling, execution, principal risk, custody, settlement, outsourcing and post-trade responsibilities.
- Legal entity and group structure
- Products, instruments and target clients
- UK nexus and cross-border activity
- Exemptions, exclusions and perimeter risks
02
Permission and investment-type mapping
We align the proposed service with the regulated activities and investment types that may be required, avoiding both gaps and unnecessarily broad permissions.
- Advising and arranging activities
- Dealing as agent or principal
- Managing investments
- Safeguarding and administration
- Operating an MTF or OTF
03
Client classification and distribution
We document who the firm will serve, how clients will be classified, how services will be marketed and which conduct obligations are triggered across each channel.
- Professional clients and eligible counterparties
- Elective classification processes
- Financial promotions and introductions
- Conflicts, inducements and disclosure controls
04
Regulatory business plan
We develop a coherent business plan that explains what the firm will do, why the model is viable and how governance, staffing, capital, technology and controls support the proposed permissions.
- Market strategy and commercial rationale
- Revenue model and three-year forecasts
- Operational workflow and responsibility mapping
- Risk register and control ownership
Key principle: the investment types, client categories and permissions selected in the application should be supported by the contractual model, operating procedures, financial forecasts and regulatory business plan.
GOVERNANCE AND FINANCIAL READINESS
Build the firm that the application describes
The FCA assesses whether the applicant is ready, willing and organised. Policies alone are not enough: the firm needs credible people, decision-making arrangements, financial resources, systems, controls and evidence that the model can operate safely from authorisation.
05
Governance, controllers and SM&CR
We help structure the board, senior management responsibilities, control functions, reporting lines, committees and governance evidence expected for the proposed scale and risk profile.
- Controllers and ownership evidence
- Senior Managers and responsibilities
- Fit and proper assessments
- Conflicts and independent challenge
- UK substance and decision-making
06
Prudential classification and resources
We assess the applicable prudential framework and prepare the financial evidence supporting the firm's own-funds, liquidity, risk and wind-down position.
- MIFIDPRU or other applicable regime
- SNI or non-SNI assessment where relevant
- Permanent minimum, fixed overhead and K-factor considerations
- ICARA, stress testing and liquid asset planning
- Orderly wind-down resources
07
Client money, custody and CASS
Where the model touches client money or custody assets, we identify the relevant permissions, CASS implications, banking and custody arrangements, reconciliations and oversight responsibilities.
- Client money and asset flow mapping
- Third-party bank and custodian due diligence
- Reconciliation and recordkeeping design
- Acknowledgement letters and contractual controls
- CASS governance and breach escalation
08
Systems, outsourcing and operational resilience
We connect the technology architecture to the regulated activity and document how the firm will govern outsourced services, cybersecurity, business continuity and operational disruption.
- Critical systems and data flows
- Outsourcing register and supplier oversight
- Access controls and incident management
- Business continuity and disaster recovery
- Impact tolerances and resilience testing
MARKET ACTIVITY AND APPLICATION EVIDENCE
Translate the operating model into submission-ready evidence
Different wholesale activities require different supporting materials. We organise the application around the actual model, not a generic policy library, and prepare the evidence needed to demonstrate how the firm will meet its obligations in practice.
09
Trading venues and market infrastructure
For MTF, OTF and other market-facing models, we support the preparation of venue rules, participant criteria, execution arrangements, surveillance, transparency controls and governance documentation.
- Non-discretionary or discretionary execution model
- Admission and access rules
- Order interaction and matching methodology
- Pre-trade and post-trade processes
- Market abuse monitoring and escalation
10
Application forms and supporting documents
We prepare and review the forms, schedules and attachments required for the relevant firm type and permission profile.
- Regulatory business plan and programme of operations
- Financial forecasts and prudential calculations
- Governance, controllers and individual forms
- Compliance monitoring and risk frameworks
- IT, outsourcing and operational resilience evidence
11
FCA questions and information requests
We help maintain a controlled response process during assessment, update documents consistently and prepare clear explanations when the FCA requests further information or challenges an aspect of the model.
- Response tracking and ownership
- Evidence updates and version control
- Clarification of permissions and financial assumptions
- Preparation for meetings and interviews
12
Post-authorisation readiness
Authorisation is the beginning of the regulated operating cycle. We help the firm convert application commitments into a launch plan, reporting calendar and practical compliance programme.
- Conditions and implementation actions
- Regulatory reporting and notifications
- Training and governance calendar
- Compliance monitoring and board reporting
- Variation of permission planning
Corporate finance and venue models: transaction advisory, admissions to trading, private placements, mergers and acquisitions, MTF operation and OTF operation may involve materially different permissions, conduct rules, prudential treatment and supporting evidence.
OUR WORKING PROCESS
A controlled route from perimeter assessment to submission
The work is sequenced so that permissions, business plan, financials, governance and policies describe the same firm. This reduces contradictions and allows gaps to be identified before the application is submitted.
Initial model review
We review the proposed activities, legal structure, clients, products, transaction flow, technology and geographic reach.
Permissions and gap analysis
We define the likely permission profile and identify gaps in governance, staffing, capital, documentation and controls.
Application architecture
We build the regulatory business plan, financial model, forms, policies and evidence around one consistent operating model.
Readiness review
We test the application package for consistency, completeness, governance ownership and operational credibility.
Submission support
We support finalisation, submission management and responses to FCA questions and information requests.
Launch preparation
We help translate the approved model into reporting, monitoring, training, governance and post-authorisation controls.
NEXT STEP
Prepare the correct wholesale markets authorisation strategy
Begin with a focused review of the proposed business model, permissions, prudential position and application readiness.
This service provides regulatory preparation and application support. FCA authorisation decisions remain solely with the Financial Conduct Authority. The applicable permissions, rules, prudential requirements, forms and fees must be confirmed for the applicant's specific business model and at the time of application.