At the beginning of May this year the Financial Conduct Authority announced a change in the process to notify requests for marketing authorisations under the UK NPPR. As part of this change, notifications will not be made any longer using an excel form to be emailed to a dedicated address of the FCA. Instead, from now notifications for UK NPPR will be made via the Connect Platform of the UK FCA. Please find a link here to the official update of the UK FCA.
In this brief post we will explain how to register to the Connect Platform as well as which type of UK NPPR is affected.
The Connect Platform
The Connect Platform became known to fund managers and other investment service providers in the aftermath of the introduction of the Temporary Permission Regime (TPR) in the United Kingdom at the beginning of 2019 (please find out more about the TPR here). This platform was in fact assigned and used already for TPR related notification of funds already authorised for marketing in the United Kingdom under the EU marketing passport, in order to avail of the relevant marketing extension granted under the TPR.
The success of the platform triggered the change in approach by the UK FCA, which now extended the use of this platform to certain, but not all, marketing notifications under the NPPR in UK. Whilst the previous process was relatively straightforward itself, the use of the platform will streamline further some of the aspects related to the notification, as we will see further down.
Register to notify UK NPPR via the Connect Platform
The Connect Platform requires simple user access registration. Depending on whether the firm has already received any sort of authorisation by the UK FCA – and a Firm Reference Number (FRN) has been issued accordingly – there are two types of user registration. For firms that are registering to the Connect Platform for the first time, the image above gives an indication of the information required for the registration. The platform gives the ability for multiple user access, so that once the main user is created, additional users can be added also external to the firm. Please find the link to register to the Connect Platform here.
Types of UK NPPR To Use the Connect Platform
Not all types of UK NPPR Notifications will have to be made through the Connect Platform from now on. The new requirement in fact will apply to the following UK NPPR notifications only:
- Notification under article 57 – corresponding to article 36 AIFMD (EU or UK AIFMD marketing non-EU AIF);
- Notification under article 58 – marketing by small third country AIFMs;
- Notification under article 59 – corresponding to article 42 AIFMD (non-EU AIFM marketing non-EU AIF).
Notification of Material Changes and Payment of Fees for UK NPPR on Connect Platform
The Connect Platform will also be used for notification of material changes to marketing notifications under the UK NPPR as well as for payment of fees by means of a debit of credit card. This is a welcome change given that the payment of fees was one of the weak points of the previous system.