The Questions FCA Case Officers Ask Most Often 

You have spent months preparing your FCA application. The business plan has been refined, the regulatory business plan has gone through more versions than anyone cares to count, and every document has been reviewed and re-reviewed. You finally submit the application and breathe a sigh of relief. 

Then the phone rings. 

Or perhaps an email lands in your inbox from the FCA case officer asking for a discussion. Suddenly the confidence that accompanied submission starts to evaporate. What have they found? Have they spotted a problem? Is the application in trouble? 

In most cases, the answer is no. 

One of the biggest misconceptions about the FCA application process is that additional FCA case officer questions mean something has gone wrong. In reality, FCA case officer questions are often a normal part of the process. The regulator is not simply reviewing documents; it is trying to understand the people, business and risks behind them. 

The FCA wants to bring your application to life. 

Why FCA Case Officer Questions Are Asked

Whether you are applying for authorisation, seeking a variation of permission, progressing a change in control application, or submitting a Senior Managers application, the FCA’s role is ultimately the same. 

It wants to understand how the business will operate, who is responsible for key decisions, what risks exist, and how those risks will be managed. 

This means that even a well-prepared application may generate questions. A business plan can explain a strategy on paper, but the FCA often wants to understand how that strategy works in practice. A governance chart can identify reporting lines, but it cannot always demonstrate whether senior managers genuinely understand their responsibilities. 

The regulator is assessing competence, understanding and credibility just as much as documentation. 

That is why receiving questions should not immediately trigger panic. Although admittedly, many firms still react as though they have received an unexpected letter from the taxman. 

It’s not always the applicant who gets the call 

One area where firms are sometimes caught off guard is Senior Managers applications. 

Many of the FCA case officer questions we see relate to Senior Managers applications and the suitability of the individuals involved.

Historically, much of the focus has been on SMF16 and SMF17 applications, where formal or informal interviews have often formed part of the FCA’s assessment. More recently, we have seen an increase in the FCA seeking discussions relating to SMF3 applications as well. 

Interestingly, it is not always the incoming candidate who is contacted. 

The FCA may speak to the outgoing SMF16 or SMF17 holder to better understand why they believe the proposed successor is suitable for the role. It may ask questions about handovers, experience, competence and the firm’s reasoning behind the appointment. 

Sometimes these discussions are formal interviews. Sometimes they feel more like an informal telephone conversation. 

The distinction matters less than many people think. 

Any interaction with the FCA should be treated as if you are on the record. A seemingly casual discussion can still influence the regulator’s understanding of the application and the firm’s governance arrangements. 

Governance questions are rarely about governance charts 

Governance-related FCA case officer questions are often less about organisational charts and more about whether individuals have sufficient capacity to fulfil their responsibilities.

When firms think about governance questions, they often focus on reporting lines, committee structures and Management Responsibilities Maps. Those topics certainly arise, but one of the FCA’s most common concerns is much more practical: does the proposed Senior Manager actually have the capacity to fulfil the role? 

This is particularly common in SMF applications, whether submitted as standalone approvals or as part of a wider authorisation, variation of permission or change in control application. The FCA recognises that, particularly in smaller firms, individuals often wear multiple hats. Being an SMF, adviser, business owner and occasional IT support technician is not unusual. The issue is not the number of responsibilities someone has; it is whether they can realistically discharge them all. 

Case officers will often explore how a candidate spends their time, what responsibilities they will retain, how they oversee key risks, review management information and maintain effective oversight. They may also ask who provides support, what happens during periods of absence and how accountability is maintained in practice. 

There is no universal answer. What is appropriate for a small directly authorised firm may look very different in a larger, more complex organisation. However, candidates should be able to explain clearly how they manage their responsibilities and why they have sufficient time and resource to undertake the role effectively. 

This is an area where vague assurances rarely help. Telling the FCA you will “make time” for your SMF responsibilities is unlikely to carry much weight. The regulator wants evidence that sufficient capacity already exists and that accountability can be exercised effectively in practice. 

Ultimately, the FCA is looking beyond governance charts and job titles. It wants reassurance that the individual accepting accountability has the time, oversight and support needed to fulfil it. That is often where the real scrutiny begins. 

The business plan should belong to the business 

One of the most common areas FCA case officers explore is the business plan. Not necessarily because they think there is something wrong with it, but because they want to understand whether the people responsible for delivering it genuinely understand it. 

The FCA appreciates that firms often use consultants to help prepare applications. What matters is not who drafted the document, but whether the senior managers can explain the assumptions behind it, the risks it identifies and the controls that support it. A business plan should reflect the reality of the business, not an idealised version of what the firm hopes to become. 

Case officers will often move beyond the document itself and test how well applicants understand the detail. They may ask about client acquisition, operational processes, compliance oversight, growth assumptions or risk management arrangements. They are looking for evidence that the plan is owned by the business, not simply submitted by it. 

This is where some firms struggle. A polished application carries little weight if the people leading the business cannot explain how it works in practice. Put bluntly, if a senior manager cannot answer questions on the business plan, it is difficult to argue that they are equipped to deliver it. 

Good consultants help firms articulate their strategy, challenge assumptions and strengthen their controls. They do not operate a regulatory sausage factory, producing generic documents that look impressive until the FCA starts asking questions. Ultimately, the regulator is assessing the understanding behind the plan just as much as the plan itself. 

How To Prepare For FCA Case Officer Questions

Preparation is essential, but over-rehearsal can be just as unhelpful as no preparation at all. 

Senior managers should understand the application, know the key risks, be familiar with governance arrangements and be able to discuss customer journeys with confidence. They should also appreciate that regulator conversations often move beyond the content of a document and into the rationale behind it. 

The strongest applicants are usually those who can explain their business clearly, honestly and consistently. 

Ultimately, FCA case officer questions should be viewed as an opportunity rather than a threat. They allow firms to demonstrate competence, credibility and understanding beyond the pages of an application. 

If your firm is preparing for FCA authorisation, a variation of permission, a change in control application or a Senior Managers approval, preparing for FCA case officer questions can make a significant difference to the outcome. 

At B-Compliant, we help firms prepare for exactly these conversations, ensuring that applications are not only well documented but genuinely understood by the people responsible for delivering them. Because when the FCA calls, the best answer is not a perfectly rehearsed one. It’s a confident explanation from someone who truly knows their business.