What Actually Goes Wrong in Form A Submissions

A Form A that clears without follow-up questions and one that drags on for months asking the same underlying question: has the firm actually done the work to show this candidate is fit and proper, or has it asserted that they are and hoped the paperwork would carry it? We see the same handful of causes behind delayed submissions again and again, across firms and across designations. This guide sets out what they are and how to avoid them.

The Assessment Was Done After the Hiring Decision, Not Before It

This is the single most common root cause of a difficult Form A process. A firm identifies its preferred candidate, makes an offer, and only then turns to compiling the fitness and propriety evidence the application requires. By that point, the firm has an obvious incentive to present the evidence in the most favourable light possible, and the resulting submission often reads as advocacy rather than assessment — which is precisely what invites regulator scrutiny and follow-up questions. Submissions built from an assessment genuinely conducted during the search, before any hiring decision was made, read differently, and clear more smoothly, because they reflect a firm that tested the candidate rather than one justifying a decision it had already made.

Gaps or Ambiguity in Employment History

Unexplained gaps, vague descriptions of previous roles, or discrepancies between what a candidate’s CV says and what a reference actually confirms are among the most common triggers for follow-up questions. This doesn’t mean every gap is a problem — career breaks, redundancies and sabbaticals are entirely normal — but every gap needs a clear, consistent explanation the firm has actually verified, rather than one the firm has simply accepted at face value from the candidate.

Regulatory References That Don’t Match the Story Being Told

Since the introduction of mandatory regulatory references, firms are required to request structured references from a candidate’s previous FCA or PRA-regulated employers covering the past six years, and those employers are required to respond accurately, including flagging any conduct issues or breaches. A submission that presents a clean narrative while a regulatory reference tells a different story is one of the fastest routes to a stalled Form A. Firms should request regulatory references early in the process — not late, once an offer has already been extended — precisely so that any discrepancy surfaces while there’s still time to understand and address it.

Weak or Generic Statements of Responsibilities

A Statement of Responsibilities that’s vague, generic, or copied with minimal adaptation from a template is a signal to the regulator that the firm hasn’t genuinely thought through what this specific individual will actually be accountable for. A strong Statement of Responsibilities is specific to the firm’s actual structure, names concrete accountabilities rather than generic categories, and has no material overlap or gap with the Statements of Responsibilities of the firm’s other SMF holders. Getting this document right takes real time, and firms that rush it as a final administrative step rather than building it carefully during the search consistently generate more regulator queries.

Insufficient Explanation of Prior Regulatory History

A candidate with any prior regulatory history — a previous firm’s supervisory finding, a past complaint, an earlier SMF role at a firm that later had governance issues — needs that history addressed directly and thoroughly in the application, not glossed over in the hope it won’t come up. The FCA has full visibility of a candidate’s regulatory history independent of what the firm chooses to disclose, and an application that appears to minimise or omit a known issue reads far worse than one that addresses it head-on with a clear, honest account of what happened and what the candidate learned or changed as a result.

Competence Evidence That’s Asserted Rather Than Demonstrated

“The candidate has extensive experience in this area” is an assertion. A submission that instead points to specific, verifiable examples — particular achievements, quantified outcomes, named prior roles with dates and reporting lines that a reference can confirm — gives the regulator something concrete to assess rather than a characterisation to take on trust. This is exactly the distinction between a search that tested for the specific SMF accountability throughout the process and one that assessed general seniority and is now trying to translate that into fit and proper language after the fact.

The Practical Fix

Every one of these failure patterns traces back to the same root cause: treating the fit and proper assessment as a final compliance step rather than the organising principle of the search itself. Firms that build the assessment in from the first candidate conversation — verifying employment history as they go, requesting regulatory references early, drafting the Statement of Responsibilities specifically and carefully, and addressing any regulatory history directly rather than hoping it doesn’t surface — consistently produce Form A submissions that clear in the expected timeframe.