When you apply for consumer credit authorisation, the FCA doesn't only assess your business — it assesses the people who own and run it, against what's known as the fit and proper test. For a limited permission firm that assessment centres on the person holding the SMF29 function, along with directors and significant owners.
What the fit and proper test actually covers
The test has three strands. Honesty, integrity and reputation — convictions, regulatory findings, disqualifications, and whether you've been straight in your dealings. Competence and capability — whether you can actually run the regulated activity you're applying for. And financial soundness — which is where CCJs, defaults, IVAs and bankruptcy come in.
Notice what the test is not: it is not a credit score with a pass mark. The FCA is asking whether the people behind the firm can be trusted to run a regulated business honestly and competently. Financial difficulty in your past is evidence to be weighed, not a verdict.
CCJs, defaults and bad credit
A satisfied CCJ from several years ago, with a sensible explanation and clean conduct since, is a very different thing from a string of recent unsatisfied judgments. What the FCA looks for is the pattern and the response: what happened, why, how you dealt with it, and what your position is now. A single historic CCJ that you disclose, date and explain is routinely survivable.
Bankruptcy, IVAs and failed companies
A discharged bankruptcy or a completed IVA sits in the same category: relevant, disclosable, and assessed in context — how long ago, what caused it, and how your affairs have run since. Directorships of companies that failed or were dissolved also come up, and the FCA can see them at Companies House whether you mention them or not. An honest account of a business that didn't work out is normal commercial history. Undisclosed insolvent liquidations are something else entirely.
The serious end of the scale is different in kind: an undischarged bankruptcy, a live director disqualification, or convictions involving dishonesty. These go to the heart of the test and will weigh heavily — if that's your position, take proper advice before spending the non-refundable £560 application fee.
The mistake that actually kills applications
Non-disclosure. The application asks direct questions about convictions, insolvency, judgments and past directorships, and the FCA checks the answers against Companies House, the Insolvency Register, its own intelligence and criminal records checks. A CCJ you disclose is a financial-soundness data point. A CCJ you conceal becomes an integrity finding — and integrity is the one strand of the test with no sympathetic reading. Applications fail on the cover-up, not the event.
How to disclose well
Treat every disclosure as three sentences: what happened, with dates and amounts; why it happened; and what has happened since. Attach the paperwork if you have it. A disclosure written this way reads as exactly what it is — a business owner being straight about their history — and it lets the case officer close the point instead of opening an investigation. It also feeds a stronger regulatory business plan, because the FCA's real question is always about the future, not the past.
How we handle it
Our questionnaire asks the adverse-history question up front, in confidence, precisely because knowing first lets us present it properly. We review any disclosure before work begins; in the rare case we conclude we can't act, your deposit is refunded in full. What we will never do is help anyone leave something off the form — because it doesn't work, and because it turns a survivable history into an unanswerable integrity question.