Published: 14th November 2017


Of relevance to: Any firms applying for FCA authorisation or Variation of Permission
Key date: Applications prior to 31 December 2017

Firms impacted by MiFID II should by now have applied for authorisation or for Variation of Permission (“VoP”), otherwise they risk being unable to operate in the UK market when MiFID II takes effect on 3 January 2018, as the FCA does not guarantee to determine applications in time for new permissions to be in place by that date.

If you have not yet applied at all, you urgently need to submit an application with all the information the FCA requires.

Any firm applying for a VoP in order to be compliant with MiFID II (and anyone newly applying for authorisation) must include contingency plans in their application in the event it is not in place by 3 January 2018, given that firms can only carry out MiFID II activities for which they have the appropriate regulatory permissions.

Where the FCA becomes aware of firms carrying on regulated activities without the required permissions, it may take appropriate action. Firms that carry on MiFiD II activities without the necessary permissions may face civil, regulatory and/or criminal consequences.

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