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Home > Prudential Regulation Authority > New Bank Start-up Unit > New Bank Start-up Unit - Application
 

New Bank Start-up Unit - Application

What happens when you apply to become a new bank? - Application

​​After the pre-application meetings, including the challenge session, you should be ready to submit your formal application for us to assess and decide whether to authorise your new bank.

This section covers the things you need to do to submit your application, and what happens next, including:

You may also find it useful to refer to the FAQs, and the After Application page which includes information on Internal Capital Adequacy Assessment Process (ICAAP) and the Internal Liquidity Adequacy Assessment Process (ILAAP).

 Where can you find forms?

 You can find all the forms you need to complete on the Bank of England's website

Before you submit your application, you should review it to check you have provided adequate responses to all questions and enclosed any supporting documents. We also strongly recommend that you address all the issues and actions we have identified with you during the
pre-application stage before you submit your application.

It is important to always be open and honest with us as the success of your application will be affected if we find you have deliberately withheld information or provided false or incomplete facts. You should also provide us with any other information that you think we should be aware of. If you are in doubt about anything, then please disclose it. If the information you provide is inaccurate, or incomplete, this will delay your application.

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 What happens when you submit your application?

 

When you submit your application you will need to send the PRA (see Contact Us) for where to send your application:

  • two printed copies of all of the documents; 
  • two electronic copies of all of the documents (on a memory stick, DVD, or other method); and
  • a cheque made payable to the Financial Conduct Authority for the application fee of £25,000. Further details are available in Section 10 of the application form available here.

When we receive your application at the PRA we will:

  • log your application and distribute copies to the FCA; and
  • assign case officers from the PRA and FCA, who will usually be the same people who guided you through the pre-application stage.

You should expect to receive written confirmation of receipt of your application from the PRA along with confirmation of your case officers within five working days. This confirmation will also briefly outline the assessment process. The key points are that we will:

  • assess your application including whether it is complete or incomplete (see ‘What will we assess?’ and ‘Why is completeness important?’ below), and whether you will meet and continue to meet each regulator’s Threshold Conditions (see ‘What are the Threshold Conditions?’ below);
  • arrange a formal monthly catch-up call with you. This is a chance for all parties to update on progress and discuss any issues;
  • interview a number of senior management and non-executive directors, in line with current regulations (see ‘Who will we interview?’ below);
  • be in touch if we want to visit you; and
  • write to you, usually within eight weeks, with the results of this assessment and, if necessary, ask for any outstanding information.
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 What will we assess?

 
We will review the following information as part of our assessment:
  • business plan/viability;
  • financial resources, as appropriate;
  • sources of funding;
  • owner and controllers;
  • corporate governance;
  • risk management;
  • customer journey;
  • outsourcing;
  • IT;
  • policies and procedures;
  • recovery and resolution, as appropriate; and
  • business continuity.

We will also set the capital and liquidity levels you will need to hold based on the Internal Capital Adequacy Assessment Process (ICAAP) and the Internal Liquidity Adequacy Assessment Process (ILAA) which you submit as part of your application. The PRA’s decisions will be communicated to you in writing, either in the letter with the results of our assessment or separately (as appropriate).

This assessment is not applicable for non-EEA branches. However, the PRA will look at capital and liquidity on a whole firm basis.

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 Why is completeness important?

 
When you do submit an application, the first assessment we will make is whether your application is complete or not. This affects the statutory deadline by which we must make a decision on your application as follows:
 
  • Complete applications - we have a six month statutory deadline to assess an application that has been deemed complete.
  • Incomplete applications - we have a 12 month statutory deadline to assess an application which has been deemed incomplete.

For your application to be assessed as complete you will need to have provided us with all of the required application forms, which have been fully and correctly completed, and the information provided must be of sufficient quality and detail to allow us to complete our assessment. We also expect you to have incorporated responses to our feedback provided during the pre-application stage.

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 What are the Threshold Conditions?

 

We will assess whether – on the information provided in your application - as an authorised firm you will meet and continue to meet each regulator’s Threshold Conditions.

The PRA’s Threshold Conditions for banks are:​ The FCA’s Threshold Conditions for banks are: ​
  • ​Legal status
  • Location of offices
  • Prudent conduct of business
  • Suitability
  • Effective supervision
  • ​Effective supervision
  • Appropriate non-financial resources
  • Suitability
  • Business model

   

There are clearly a number of similarities between each regulator’s. The PRA assessment will focus on its statutory objective to promote the safety and soundness of banks. The FCA’s assessment will focus on its statutory objectives of protecting consumers; protecting and enhancing the integrity of the UK financial system; and promoting effective competition in the interests of consumers. More detail on the PRA’s and FCA’s Threshold Conditions is available here.

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 Who will we interview?

We will assess applicants for key roles in your bank to make sure they are suitable for the role and have the skills, capabilities and behaviours required. We may invite them for an interview. The interviews are designed to ensure that individuals taking on senior roles at authorised firms are aware of their responsibilities. It is also a chance for the regulators to look at a candidate’s knowledge of the firm and the sector that it will operate in.

Typically, we will consider interviewing those applying for these roles:

  • Senior independent director
  • Chair of Risk and/or Audit Committee
  • Chief Executive Officer
  • Head of Branch (for branches of non EEA-firms)
  • Risk Director/Chief Risk Officer
  • Finance Director/Chief Finance Officer

For banks that are not branches our assessment will also consider how appointments to the board will contribute to a balanced and effective board at your new bank.

If we have any concerns we can choose to interview a role at any level in the firm. 
 
Interviews explained​
​Interviews will be held at either the PRA’s or FCA’s offices in London and can take up to 90 minutes. The composition of the interview panel will be determined on a case-by-case basis and will usually include senior representatives from both regulators along with your case officers.

We expect the candidate to understand and be able to explain fully their regulatory responsibilities, their role and how their skills, knowledge or previous experience equips them to carry out the role.
 
 
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 How long will it take to give you a decision on your application?

We will endeavour to assess an application and reach a decision within six months. This is a voluntary deadline that both the PRA and FCA will try to meet but it is not guaranteed. Throughout our assessment we may have queries or require further information from you. You can help to make the process as efficient as possible by responding promptly and comprehensively to our queries.

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  The decision

Both regulators will make a decision independently on whether or not to authorise your new bank. While the PRA will make the final decision on your application, it may only authorise a new bank with the FCA’s consent. If the FCA does not provide its consent, the PRA will be unable to authorise your bank.
 
Your case officers will make a recommendation to approve or refuse your application. The decision to approve or refuse your application also incorporates the recommendation, or not, of all senior managers or any other transactions linked to your application (such as waivers).
 
The decision to authorise a firm is made by an independent decision maker at each of the regulators. Your case officers will not decide whether to approve or reject your application.
 
If we decide to approve your application, we will be in touch with you and include the following:
 
  • Authorisation Letter - which will include the details of any restrictions you are subject to, in particular if you are taking the mobilisation route;
  • Scope of Permission Notice – which is your Part 4A permission and will set out the date from which the permission has effect, which regulated activities you have permission to carry on and any requirements or limitations; and
  • Welcome pack.
 
You will also see your bank’s details on the Financial Services Register from the date you will be authorised as shown in the Authorisation Letter.
 
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 What happens if your application is not approved?

If it looks likely that we’re going to refuse your application, we will let you know both orally and in writing, giving you time to address our concerns. If you are unable to address these concerns, we will issue you with a ‘minded to refuse’ letter, which will set out our concerns and detail which Threshold Conditions and/or specific rules have not been satisfied.
 
If you are unable to address our concerns, you may decide to withdraw your application and reapply when you are in a position to do so.
 
However, if you decide that you wish to proceed, we will escalate your case for a decision by senior management at both regulators. If they agree with the case team’s recommendation (to propose to refuse the application), the PRA or the FCA, as the case may be, will issue you with a Warning Notice. At this stage, you will still be able to either withdraw your application or make representations (orally and/or in writing) to the relevant PRA or FCA decision makers. If they do not agree with the case team’s recommendation, the case will be referred back to your case officers who will resume assessing your application.
 
If you decide to make representations, the relevant PRA or FCA decision makers will take your representations into account in deciding whether or not to refuse the application. If the decision makers decide not to issue a Decision Notice, your application will be referred back to your case officers who will resume assessing your application.
 
If, having heard any representations, the decision makers decide to refuse your application, a Decision Notice will be issued to you. The Decision Notice will notify you of your right to refer the decision to refuse your application to the Upper Tribunal (Tax and Chancery Chamber). If you decide not to refer the Decision Notice to the Tribunal, the PRA will issue you with a Final Notice and details of this may be published on the PRA’s website.