For any financial services business, the process of selecting a name is not a straightforward process…
The team at RWA regularly receives questions on the topic of trading names and what, if anything, needs to be done; so I thought it may be useful to remind you what the FCA expects.
Firstly, the FCA has no problem with trading name / styles for a regulated firm, but be careful if you want to include what is termed a ‘Sensitive Business Name’ as the FCA must approve this before you use it.
The list of sensitive names is as follows:
- assurance
- assurer
- banc
- bank
- banking
- building society
- cooperative and community benefit societies
- credit union
- friendly society
- fund
- industrial and provident society
- insurance
- insurer
- mutual
- reassurance
- reassurer
- reinsurance
- reinsurer
- underwrite
- underwriting
So, for example, if you are called Manchester Insurance Brokers Ltd, and want a trading name/style of say, Best Manchester Insurance, you must apply for permission.
In this example, I would say that permission would be refused as it is not clear if you are an insurer or not!
An alternate option would be to use ‘Best Manchester Insurance Brokers’ or ‘Advisers’ or similar, as there must be sufficient distinction in the name to indicate what you do.
The FCA has a dedicated page, including details on how to apply for use at: https://www.fca.org.uk/firms/standing-data/sensitive-business-names
If you do not use one of the terms on the list, there is no need to get pre-approval and you can go straight to CONNECT to put in your addition of a trading style.
You should also advise the Information Commission as well (a short email usually suffices).
Once all up and running, do not forget to amend your authorisation statement immediately on all your literature, stationery, websites, social media, etc.
Using the example above, it should now read as:
Manchester Insurance Brokers Ltd t/a Best Manchester Insurance Brokers
is authorised and regulated by the Financial Conduct Authority.
Or
Best Manchester Insurance Brokers is a trading style of Manchester Insurance Brokers Ltd,
which is authorised and regulated by the Financial Conduct Authority.
If you need any guidance, speak to your RWA Business Manager.
Terence Clark
Chairman
