Sample business plan

Provide as much detail as possible relating to the company.

For example:

• the firm’s principal place of business and legal status
• whether the business is incorporated
• how long the firm has been trading for
• what the firm’s website address is
• what the firm’s control structure is (we need to see full details of this)
• whether you're a sole trader – sole traders generally:
  • have the right to make all decisions affecting the business
  • own all the assets of the business
  • are responsible for paying income tax on profits of the business
  • are responsible for the debts and obligations of the business without any limit

Our Consumer Duty[2] ('the Duty') sets the standard of care that firms should give to customers in retail financial markets. It reflects our expectations of firm conduct, and means that your firm must consider customer outcomes and place customers’ interests at the heart of your activities.

The Duty should feature throughout your business plan. To help us assess whether you can comply with the Duty, read more about the requirements for firms seeking authorisation[3].

If your firm isn't in scope of the Duty

You'll need to explain why (so we can see that you've considered it) and demonstrate how you'll comply with Principles 6 and 7[4] in our Handbook, which continue to apply to firms that aren't subject to the Duty.

Read more about the fair treatment of customers[5].

We require information on the key personnel of the firm. Please provide detailed information on each individual’s role and the management responsibilities they will have.

For example:

• who will be carrying out the day to day running of the business
• who are the director(s)/proprietor(s) of your firm, and key persons
• what senior management functions (SMFs) will each individual hold
• who will be responsible for compliance oversight
• what experience your firm’s governing body or senior management has of the regulated activities that you wish to carry out
• what the background and experience is of everyone performing SMFs (including their employment)

Provide an in-depth explanation of what your firm does and the activities your firm will be carrying out.

For example:

• what services (both regulated and non-regulated) your firm will provide, as well as the areas the firm specialises in
• why your firm requires authorisation for the activities it will undertake
• details of any relationships/agreements with lead generators or brokers
• if your firm is trading, provide details on your existing customer base and how the regulated activities proposed will impact on these customers
• what your firm’s long-term strategy is (eg growth targets, changes in personnel)
• whether the firm will hold any client money
• details of any fees and how they are explained to the customer

Set out your marketing plans and any financial promotions that your firm may be using or is planning to use.

Provide details of the customer journey from the very beginning of acquiring the customer to the after-sales care process service that your firm provides.

For example:

• how your firm obtains new clients
• whether your firm is acquiring any existing clients from another firm
• what your firm’s ongoing client relationship is
• providing a step-by-step guide of the journey a customer takes for the sale/service
• what the after-sales care process is

Provide further information about your firm’s approach to identifying, and meeting the needs of, customers in vulnerable circumstances.

For example:

• how your firm identifies when a customer is in a vulnerable circumstance
• what your firm’s process is when dealing with customers in vulnerable circumstances
• what services are offered to customers who find themselves in vulnerable circumstances
• if your firm has a detailed document for this policy, please provide this as a supporting document

Provide detailed information of the compliance structure your firm has in place.

For example:

• whether your firm uses a third-party compliance firm to assist in this area, and, if so, provide the details of this arrangement and set out the oversight that the firm has in place
• what quality assurance processes are in place for your firm
• what key risks have been identified and how your firm will mitigate these risks
• whether your firm has a risk-based compliance monitoring programme

Provide details of your firm’s complaints process.

For example:

• how the firm will monitor complaints
• what will happen when a customer isn't satisfied with your firm's resolution
• if your firm has a detailed document for this policy, please provide this as a supporting document

Refer to the DISP rules[6] in our Handbook for more information.

Give details of the training that you'll provide to staff.

For example:

• how your firm will ensure staff are sufficiently trained to deliver the requested activities in line with the regulatory requirements
• whether your firm will hold any refresher training, and, if so, how often
• whether your firm will provide specialist training in relation to specific products 
• whether your firm's training material covers vulnerable customers and the complaints policy

Explain whether your firm will offer incentives to staff, and, if so, provide details of what your firm bases the incentives on.

This might include productivity, quality, compliance caveats, customer feedback, etc.

Explain how your firm will hold sufficient capital to meet the relevant capital resource requirement.

The information here should corroborate with the financial information you send us as part of your application.

Read more about preparing your firm's financial information[7].

Provide an overview of the policies and procedures you have in place that are relevant to your firm's business model.

If you're a credit or mortgage broker or lender, learn what supporting material[8] you need to include with your application.