Distribution-Only Funeral Plan FirmsGuide to applications and ongoing compliance

Conducts funeral plan distribution only, without undertaking other regulated funeral plan activities; direct authorisation and any applicable AR route must be confirmed separately.[1]

Select the minimum sufficient combination of permissions that lawfully supports the actual business, client scope and financial responsibilities, rather than treating the broadest permissions or fastest approval as the sole objective.

• Before selling or assuming obligations under a scheme, clarify the regulated activities, safeguarding arrangements and responsible persons, avoiding presenting ordinary company registration as financial authorisation.[1]

• Separate plan assets, standalone company finances, capital and cash flows to provide a verifiable basis for long-term performance of obligations and the firm’s solvency.[1] [2]

• Determine resource requirements according to whether the business involves provision, pure distribution or additional regulated activities, rather than merely seeking the lowest share capital figure.[2]

Applicants for direct authorisation apply through Connect and demonstrate financial resources; for AR, the actual principal assumes the corresponding responsibilities, and it cannot claim to be an independently approved provider.[1]

Shareholders, controllers, directors and those actually responsible must be reviewed under applicable authorisation, governance and fitness requirements. The institution must be able to explain actual responsibilities and its supervisory, financial and programme management capabilities, and identify functions requiring approval under the applicable senior management regime. This guide does not invent a uniform number of directors, fixed certificates or a requirement for all personnel to reside in the UK.[1]

For directly authorised distribution-only firms, the requirement under FPCOB15.6 is the higher of £10,000 and 2.5% of annual income. Firms also undertaking other regulated activities must compare the corresponding capital requirements; the AR route is reviewed separately according to the actual principal and applicable arrangements.[2]

The application should identify the actual entity, regulatory contact details, business execution and oversight arrangements, and ensure that FCA can supervise effectively. A website or registered office address alone does not demonstrate operational capability; overseas structures, outsourcing and principal firm arrangements must be consistent with the actual business plan.[1]

• Regulatory business plan, list of permissions sought, complete application forms and supporting materials.[1]

• Ownership and governance arrangements, information on proposed responsible persons, responsibilities, fitness and propriety, and applicable personnel approval materials.[1]

• The provider's plan contracts, arrangements for holding or safeguarding funds, and standalone financial information; where statutory accounts and trust accounts are consolidated, the company's standalone financial position excluding the trust must be available.[1]

• Revenue, unused plan data, capital, cash flow and adverse scenario calculations, recording key risks and mitigating measures.[2]

This is provided as a reference for organising the project; it cannot replace current official application forms or case-specific requests for additional materials. Please do not send identity documents or customer records through website forms.

• First confirm the authorisation or intermediary AR route based on the obligations actually assumed and distribution activities, and read the FCA guidance, threshold conditions and applicable FPCOB.[1]

• Prepare the business plan, staffing, financial resources and financial projections, and check that each permission matches the proposed activities.[1]

• For direct authorisation, submit a complete application and supporting materials through Connect and pay the non-refundable application fee. Providers fall within fee category 5 and intermediaries within category 4; verify current amounts on the FCA fees page, and do not treat fees as capital.[1]

• Address completeness checks, requests for additional documents and assessment requirements, and begin operations only after obtaining the corresponding approval and meeting the conditions for implementation; subsequent changes remain subject to applicable procedures.[1]

For direct authorisation, completeness and statutory decision periods must be assessed under provision 55V of FSMA and the actual application category. These are generally six months for complete applications and twelve months from initial receipt for incomplete applications, subject to any applicable statutory exceptions. This is not a guaranteed overall timetable to approval and operation; preparation, principal due diligence, funding arrangements and supplementary submissions must be allowed for separately. Acceptance of an intermediary as an AR is also not equivalent to a direct authorisation decision.[1] [3]

Adding funeral plan activities to an existing authorisation requires checking VoP. Changes in shareholdings and controllers require separate review of change-in-control procedures, while personnel changes are handled according to the actual approved functions and regulatory notification requirements. Changes to an intermediary AR's principal, scope of responsibility or operating model require separate confirmation; registration as a company director does not replace regulatory approval.[1]

Continue managing sales, advice, complaints, fair treatment of customers and financial resources; changes must be notified and handled according to actual directly authorised or AR status.[1] [2]

Before acquisition, verify the actual legal entity, FRN, permissions to provide or distribute, AR relationships and restrictions. Purchasing an ordinary company certificate does not enable the assumption of plan obligations. Reassess unused and legacy plan data, trust or insurance backing, standalone financials, revenue, capital, cash flow and performance shortfalls, and check contractual change-of-control provisions, service providers and consumer responsibilities. Where triggered, shareholding control, VoP and key personnel approvals should each be addressed before completion; regulatory consent is not guaranteed.[1] [2]

The following are specific permissions, organisational models or statutory categories covered by this topic. They do not necessarily each constitute a separate financial licence.

Primarily based on FCA, PRA / Bank of England, GOV.UK and current legislation. Older third-party guides supplied by users are used to organise business material and do not override the latest official requirements.

Information compiled by: RenGang Yongsheng (Hong Kong) Limited

Tang Shangyong (Mr Tang / Drew) · Business Manager
Global financial licence application, transaction and ongoing compliance services

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