SCENARIO A
Applying to be a regulated Pensions Dashboard Service (PDS) firm with Moneyhub
Under this scenario of providing a pensions dashboard, your organisation is the FCA regulated PDS firm, with the technology provision of the actual dashboard outsourced to Moneyhub. How is the project work split?
Collaborative delivery
This will be a collaborative project between your firm and Moneyhub. You will be in the driving seat preparing to submit a Variation of Permission (VoP) application to the FCA to become authorised as a PDS firm, but with much of the backing documentary evidence supporting your VoP application being provided by Moneyhub. The simplified table below shows the likely split of VoP information between us.
When should we start?
This is a 24-month project
See Timeline
If you want to be ready to launch your dashboard to your customers as soon as testing is complete (which could be in late 2024 or early 2025), you need to start the project now.
The later you start, the less you will be able to capitalise on being an early dashboard provider: for example, you will have a reduced ability to influence the design standards iteration during the testing phase, and you will begin losing customer primacy when your competitors launch first.
TALK TO OUR GUIDES-
1.1 Application contact: Key person employed at client
2.3 FCA fees declaration
3.3 Unregulated activities; 3.7 Firms being taken over
3.12-15 Making available the client’s PDS to other firms
4. Financial resources; 5. Systems and controls
6. Compliance arrangements; 7. Threshold conditions
8. Supporting documents updated to reflect application:
Policies: Vulnerable customers, Complaints, Compliance monitoring, Risk management and Business continuity
Financials: Y1, 2 & 3 financial projections post-authorisation, Last annual accounts, Management accounts, Loans and Other external funding
Misc: Staff structure chart, IT controls and ICO registration
9. VoP application fee payment
10. Declaration
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1.2 Desired FCA approval date: Asap to enable early connection to the PDP Central Digital Architecture (CDA) to start live testing
1.3 Reason for application: Impacts on client’s business
2.2 Scope of permissions: PDS and post-view services
3.1 Regulatory business plan
3.2/8 Customer sourcing methods & 3 year projections
3.4 Post-view services (PVSs): Details of PVSs, plus summary
of PVS user testing carried out
3.5/6 Income from PVSs
3.11 Outsourcing details
3.17/8 Ongoing Consumer Duty compliance arrangements
3.24/5 Financial promotions on the client’s dashboard
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2.1 Confirmation of compliance with all PDP and DWP standards (for core Find & View journey), including the statutory pre-connection compliance audit report by an independent expert: PDP Code of Connection: Security Standards, Service Standards and Operational Standards;
PDP Technical Standards; PDP Design Standards;
PDP Data Standards; PDP Reporting Standards;
DWP State Pension display; Regulatory complaints rules.
3.10 Data export screenshots
including evidence of how we have considered customers’ understanding of giving their consent for the data export
3.16 Evidence of how the Consumer Duty (CD) has been considered (for the core Find & View journey)