Authorisation, supervision and skilled person readiness
Regulatory attention rarely arrives at a convenient moment. A draft requirement notice lands the week your CFO goes on leave. A supervisory information request arrives in the middle of a funding round. An authorisation application that was supposed to take four months is still open at month nine.
Oakbridge Agility works with financial services SMEs, startups and scaling firms at exactly these moments, and ideally before them. Whether you are facing a skilled person review, preparing a Part 4A permission application or responding to findings already made, the task is the same in principle: understand what the regulator is actually asking, evidence what you actually do, and close the distance between the two credibly.
Preparing for a skilled person review
Section 166 of the Financial Services and Markets Act 2000 gives the FCA the power to require an independent expert report on a firm's activities. In practice, a s166 is a diagnostic instrument, used where supervision wants an evidenced view of governance, systems and controls that routine engagement has not provided. It is not enforcement, but findings can inform enforcement, and a poorly handled review is one of the most reliable ways to escalate a supervisory concern into something worse.
Effective s166 skilled person review preparation starts at the draft requirement notice, not at fieldwork. That window is short and consequential. It is where scope is negotiated, where the review period is set, and where an unrealistic timetable can be challenged before it becomes fixed.
Our support typically covers
Scope and notice response.
Reviewing the draft notice line by line, identifying scope that is broader than the underlying concern justifies, and helping you make a proportionate, evidenced case for adjustment.
Skilled person appointment.
Where the appointment is yours to make, assessing candidates for genuine relevance to your business model and risk profile. The FCA maintains a Skilled Person Panel for reviews it commissions directly; firms appointing their own can nominate a suitable supplier for approval under SUP 5.4.
Readiness assessment.
A structured examination of the areas in scope before the review begins, so that weaknesses are known to you first and are already being addressed by the time the skilled person arrives.
Evidence and data room.
Assembling board and committee minutes, MI packs, risk registers, policy version histories and decision trails, then testing whether they actually demonstrate the oversight you believe took place.
Fieldwork support.
Interview preparation for senior managers, a single point of coordination for information requests, and disciplined tracking of what has been provided.
Report challenge.
Reviewing factual accuracy at draft stage and responding to findings with a management response that is credible rather than defensive.
Reviews commonly run for several months from requirement notice to final report, and complex financial crime or historical file reviews run longer. Firms that resource that duration properly fare considerably better than those treating it as a temporary disruption.
Regulatory gap analysis
A regulatory gap analysis establishes where your firm currently stands against the rules and expectations that apply to it, and what it would take to close the difference.
We assess your governance framework, risk management, systems and controls, Consumer Duty implementation, financial crime arrangements, operational resilience and record keeping against the relevant Handbook provisions and published supervisory expectations. The output is a prioritised findings register the board can act on: what the gap is, what risk it creates, what remediation requires, and how long it will take.
A gap you have identified and are actively closing is a different conversation with a supervisor than one they identify for you. An assessment engineered to reassure the board is worse than none at all. For the case for doing this work early, read Preparing for Regulatory Scrutiny Before You Need To.
Preparing for a supervisory visit
Supervisory engagement, whether a firm visit, a thematic review or a request for information, is an opportunity to demonstrate control. It is also an opportunity to lose credibility quickly.
Our FCA supervisory visit preparation covers reviewing the agenda and information request to establish the underlying concern; preparing the senior managers who will be in the room, including realistic challenge sessions; checking the quality and completeness of the evidence pack; and rehearsing the areas where the honest answer is that work is still in progress. Supervisors are generally untroubled by a gap you have acknowledged, resourced and given a deadline. They are troubled by a firm unaware of it.
After the visit, we help you respond to feedback and track the commitments made through to completion.
Remediation after a finding
Findings, whether from a skilled person report, a supervisory letter, an internal audit or a voluntary requirement, create a delivery problem and a credibility problem at the same time.
We help boards design remediation that will withstand a second look: root cause analysis that goes past the symptom, a plan with named owners and honest timelines, MI that lets the board evidence oversight, and independent validation that the change has embedded. Where customer harm has occurred, we support redress design and oversight.
The failure mode we see most often is a plan that closes every action on paper while the underlying weakness persists. Regulators return to test exactly that.
Frequently asked questions
Facing a notice, an application or a finding?
Tell us what you are dealing with and we will set out candidly what the work involves and whether we are the right people to do it.
Arrange a confidential conversation