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Fund management compliance

CMS licence readiness is an operating-model exercise

Why governance, people, controls and evidence need to develop together during an application.

01

Beyond the application form

A capital markets services licence application is not simply a document-completion project. The materials need to describe a supportable business with suitable governance, people, controls, financial resources and operating arrangements.

The application narrative, policies, financial projections and proposed operating model should therefore be developed as connected workstreams.

02

Build the evidence while designing the business

Responsibility for each workstream should be explicit. Applicants should maintain a decision log, a controlled document set and a tracker for dependencies such as key appointments, outsourcing arrangements, technology and premises.

This makes regulatory questions easier to coordinate and helps the team move from application preparation to pre-commencement readiness.

03

The role of professional coordination

Legal, compliance, tax, accounting and operational advisers may each own different parts of the work. A central project lead helps maintain consistency, surface dependencies and keep the applicant accountable for final decisions.

Regulatory approval remains entirely at the discretion of the relevant authority.

Professional notice

This briefing is general information only. It is not legal, regulatory, tax, investment or financial advice. Treatment depends on the facts, jurisdictions and advice of the relevant qualified professional.

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