• Following submission of a completed Application Form with supporting documentation, the Central Bank acknowledges receipt of the application submission;
• The Central Bank will assess whether the application submission contains the key information and documentation required;
• Where all key information and documentation has been provided, the applicant will be asked to submit Individual Questionnaires (IQs) in respect of all proposed PCFs via the Central Bank's Portal;
• Applicants who do not already have access to the Central Bank Portal will be required to register as a user. The process for registration is available at the Central Bank portal webpage. The applicant’s Portal Administrator will then be able to provide the firm with the relevant permission to access the Fitness and Probity Section of the Portal, where the applicant will be able to complete the Fitness and Probity Profile and IQs. Where an applicant wishes to change their Portal Administrator, they should contact portalsupport@centralbank.ie;
• Applicants will also be requested to submit a Vetting Invitation Form (including proof of identity), where appropriate;
• A Garda Vetting Form is required where the applicant is a Sole Trader or a company with a single director. Please note that as An Garda Siochana operate an online eVetting process, the Central Bank will only process eVetting applications;
• Further information on the Garda Vetting Process is available on the Brokers/Retail Intermediaries, Debt Management Firms, PCF Application page of the Central Bank website;
• If you have any queries on the eVetting process please contact fitnessandprobity@centralbank.ie;
• Please do not submit Garda Vetting documentation until requested to do so.
• The Central Bank assesses whether the IQs, Vetting Invitation Forms and Vetting Application Forms have been completed and that acceptable certified proof of identity has been provided;
• Where all key information and documentation, including all relevant IQs, have been provided, the application submission progresses to the Assessment Phase (see Stage 4 below). At this point, the 90 working day Service Standards clock starts.

• The Central Bank completes an assessment of the application submission and may issue detailed comments and/or seek additional information or clarification;
• The applicant is provided with the opportunity to address the comments and requests issued by the Central Bank in a revised application submission(s). Applicants must provide a detailed and full response to comments to avoid its application being deemed dormant and withdrawn;
• The Central Bank will assess these subsequent application submission(s) and notify the applicant of its assessment and next steps.  The applicant is provided with a further opportunity to address any concerns arising at this stage in the process (if any); and
• The Central Bank will notify the applicant of the outcome of its assessment following the conclusion of the Assessment Phase. 

  Please note applicants may be moved back to the Pre-Assessment Phase in certain circumstances, for example where incorrect or misleading information resulted in an application progressing to the Assessment Phase, or, when an IQ is subsequently rejected as incomplete by the Fitness and Probity Team.

  Where an application is returned to the Pre-Assessment Phase, the Service Standards clock will be reset and the standard Pre-Assessment Phase process will recommence. 

In the sections set out below, the applicant will be able to learn about the different stages of the application process in more detail.

Applicants should submit the following documentation which should be fully completed:

• An Application Form for Authorisation as a Debt Management Firm (including the specific information / documentation requirements set out in the form);
• Individual Questionnaires (when requested to do so); and
• Where relevant, the Vetting Invitation Form (including proof of identity).

Individual Questionnaires:

Once an application is submitted and the applicant has registered as a user on the Central Bank Portal, the applicant will need to ensure that all relevant individuals proposed to hold a Pre-Approval Controlled Function (PCF) role (typically board members, senior management, key function holders) complete Fitness and Probity Individual Questionnaires. IQs must be submitted electronically via the Central Bank Portal by all relevant individuals.

It is the firm’s responsibility to ensure that it identifies all proposed PCF role holders prior to submitting an application for authorisation as a debt management firm.  Incorrect or incomplete identification of proposed PCF role holders may lead to a delay in progressing an application and/or may result in an application being moved back to the pre-assessment stage of the application process.

Please note that, for new applicants, access to the online IQ only becomes available after an application has been deemed to contain all of the key information and documentation required.

In respect of sole traders and single director companies, applicants will be invited to complete the “Garda Vetting Invitation Form” and provide proof of identity, as required by the National Vetting Bureau (NVB). Following the IQ submission, a copy of the form, including further information and guidance, will be issued by the Fitness and Probity Unit to applicants via secure message on the Portal.

Important:

• Where incomplete Application Forms, IQs or Vetting Invitation Forms (including proof of identity) or Vetting Application Form are submitted they will be returned to the applicant.
• Where IQs are not submitted within 20 working days of being requested, the application will be returned to the applicant.
• Where a Vetting Application Form is not completed within 10 working days of the request for advising the applicant to do so, the application will be returned to the applicant.
• An application will only progress to the assessment phase of the authorisation process where all key information and documentation required in the Application Form, in each relevant IQ and in the Vetting Invitation Form and Vetting Application Form (where required) has been provided.
• It is, therefore, important that the applicant has read the guidance material provided to assist applicants in completing this documentation, and has taken the information provided into consideration when completing the Application Form, the IQs and the Vetting Invitation Form (where required).

Submission of an Application 

The completed Application Form, along with all relevant accompanying material, should be submitted in electronic format to the Central Bank via Kiteworks, our secure file transfer system. Applicants must request access to Kiteworks via email to DMFAuthorisations@centralbank.ie. They will then be provided with a secure link to Kiteworks. 

A key priority for the Central Bank in assessing all applications for authorisation as debt management firms is the assessment of the applicant’s proposed Pre-approval Controlled Functions (PCF’s). Individual Questionnaires (IQ’s) in respect of each PCF role holder are assessed by the Central Bank’s Fitness and Probity Unit. These assessments are integral to the assessment of the firm's entire application.

With this in mind, firms should satisfy themselves that relevant persons meet the Fitness and Probity Standards (the Standards) for Regulated Financial Service Providers before applying for authorisation. Firms should note that compliance with the Minimum Competency Code (where applicable) is not sufficient on its own to meet the Standards.

In particular, the following sections of the Standards must be considered by each proposed applicant:

• Section 3.1 of the Standards requires a person to have the qualifications, experience, competence and capacity appropriate to the relevant function

• Section 3.2 sets out that the person must, among other things, be able to demonstrate that he or she:

1. has professional or other qualifications and capability appropriate to the relevant function;
2. has obtained the competence and skills appropriate to the relevant function, whether through training or experience gained in an employment context; and
3. has shown the competence and proficiency to undertake the relevant function through the performance of previous functions which, if carried out at present, would be subject to this Code, or current controlled functions, or performance by the person of any role similar or equivalent to the functions that are covered by this Code. 

Applicants seeking a Pre-Approval Controlled Function (PCF) role in a firm must have obtained relevant experience at an appropriately senior level prior to submitting an application to the Central Bank.

The key stages of the application process are as follows:

Stage 1 - Acknowledgement

The Central Bank will acknowledge receipt of an Application for Authorisation submitted by the applicant within 3 working days of receipt.

Stage 2 - Key Information Check

The Central Bank will then check that the application material submitted contains all of the key information and documentation required to proceed to the submission of IQs and the Vetting Invitation Form, including proof of identity (where required). Within 10 working days of receipt of the application, the Central Bank will either:

1. Advise the applicant that the application contains sufficient material to proceed to the submission of IQs and the Vetting Invitation Form, including proof of identity (where required); or 
2. Advise the applicant that the application does not contain sufficient material to proceed to the submission of IQs and the Vetting Invitation Form, including proof of identity (where required) and so is not being progressed to that phase. A statement of the omitted information is also provided to assist the applicant should it wish to submit another application in the future. Any subsequent application will be considered a new application and the application process will commence again at Stage 1.

Stage 3 - Submission of IQs and the Vetting Invitation Form (including proof of Identity)

Where sufficient information has been received, as outlined in Stage 2(1) above, the application will proceed to the submission of IQs and the Vetting invitation Form (including proof of identity)(where required). Once registered as a user on the Central Bank Portal the applicant will be required to complete and submit all required IQs and Vetting Invitation Form, including proof of identity (where required). 

The applicant will then have 20 working days to submit all IQs. If all required IQs are not submitted within 20 working days, the Central Bank will be minded to deem the firm’s application dormant and withdrawn. The applicant will be given a further 10 working days to submit the IQs. If they are still not provided within that timeframe, the firm’s application will be deemed dormant and withdrawn. Any subsequent application will be considered a new application and the application process will commence again at Stage 1.

Further information on the Garda Vetting Process is available on the Brokers/Retail Intermediaries, Debt Management Firms, PCF Assessment on the Central Bank website. 

Please do not submit Garda Vetting documentation until requested to do so.

Applicants will be advised that their applications will progress to the assessment phase of the applications process once all required IQs and the Vetting Invitation Form (including proof of identity) and the Vetting Application Form, where required, have been submitted and are deemed to contain all of the key information and documentation required.

Stage 4 - Assessment Phase

Where an application submission, all relevant IQs and the Vetting Invitation Form (including proof of identity), where relevant, have been received and have been deemed to contain all of the key information and documentation required, as outlined in Stage 2(1) and 3 above, the Central Bank will then proceed to the assessment phase of the application process.In the assessment phase, the application material submitted will be reviewed against the relevant AR&S to determine whether, or not, sufficient information has been provided to enable the Central Bank to make a decision on the application.

The Central Bank will issue initial comments to the applicant based on its review of the application material submitted and any subsequent comments, if any, based on its review of responses submitted by the applicant. Applicants will be given 20 working days to respond to initial comments and 10 working days for subsequent comments. 

The Central Bank has published Service Standards (see below) in respect of the assessment of applications for authorisation and, in this context, the Service Standard timeframe for the completion of the Assessment Phase of the application process is 90 working days (from receipt of all relevant IQs). However, it should be noted that, in the event of additional information being sought, this 90-working day 'clock' is paused until such time as this information has been submitted by the applicant.

In the event of the applicant failing to respond to a request from the Central Bank for additional information within the timeframe set out, the Central Bank will follow the dormancy process, as set out in Stage 3 above.

Stage 5 - Notification of Assessment

The Central Bank will notify the applicant of the outcome of the Assessment Phase of the application process as follows:

    a)    Where the assessment is favourable, the Central Bank will notify the applicant by letter that it proposes to authorise the applicant on the basis of the information provided in its application submission, provided that any specified final steps are taken and/or any specified final items of information and evidence are received. This letter will also specify any specific conditions that the Central Bank proposes to impose on the firm's authorisation. This letter will explain the reasons for these proposed conditions and the applicant will be afforded the opportunity to make representations in respect of the proposed conditions before the Central Bank makes any decision on the application.

b) Where the assessment is unfavourable, the Central Bank will issue a letter to the applicant to advise that it is minded to refuse the application for authorisation. In accordance with the applicable legislation, the Central Bank will notify the applicant of the grounds for the proposed refusal of the authorisation. The applicant will then have an opportunity to make submissions in response to the proposed refusal. The submissions will then be considered by the Central Bank following which a decision will be taken by the Central Bank to grant or refuse the application or authorisation. 

Stage 6 - Notification of Decision in respect of the Application

Once the Central Bank has assessed any further information/evidence/representations submitted by the applicant following on from Stage 5 above, the Central Bank will notify the applicant, via letter, of its decision on the application, as follows:

    a)     Authorisation - The Central Bank has decided to grant an authorisation.

    b)     Authorisation with Specific Conditions - The Central Bank has decided to grant an authorisation with specific conditions attached to the authorisation. The specific conditions to be attached to the authorisation will be outlined in the letter.

    c)     Refusal of Authorisation - The Central Bank has decided to refuse an application for authorisation.  Please see further details on the refusal process available on the Central Bank’s website.If the applicant has any queries in respect of the application process, it can contact the Authorisations Team at DMFAuthorisations@centralbank.ie.