Intermediary Service Platform Licensing Before the CMA

We begin with the perimeter, because the line between a licensable intermediary platform, a mere technology supplier and a business that needs a different licence altogether is drawn on the substance of the customer relationship and the movement of funds, not on what the app calls itself. We give that answer in writing, then structure the applicant, prepare the fit and proper material for its owners and officers, and build the application, the business plan, the platform and custody arrangements, the client money safeguards, the agreements with the fund managers and product providers whose products the platform distributes, and the policy suite the Authority expects. We manage the application through the Authority to grant, and we advise licensed platforms on the continuing obligations, disclosures and approvals that follow.

The product itself, shown to us as a customer would use it, the flow of customer money from deposit to investment and back, your arrangements with the underlying fund managers, and the particulars of the company and its owners. Founders who bring us the real customer journey early save themselves a redesign later.