Final Notice

On , the Financial Conduct Authority issued a Final Notice to First Call Trade Services Limited


For the reasons set out in this Final Notice, the Authority hereby takes the following
action against FCTSL.

The Authority issued to FCTSL the Decision Notice which notified it that for the
reasons given below and pursuant to section 55J of the Act, the Authority had
decided to cancel FCTSL’s permission.

FCTSL has not referred the matter to the Tribunal within 28 days of the date on
which the Decision Notice was issued to it.

Accordingly, the Authority has today cancelled FCTSL’s permission.


The definitions below are used in this Final Notice:

“the Act” means the Financial Services and Markets Act 2000;

“the Authority” means the Financial Conduct Authority;

“the Decision Notice” means the Decision Notice issued to FCTSL dated 25 July

“FCTSL” means First Call Trade Services Limited;

“FCTSL’s Part 4A permission” means the permission granted by the Authority to
FCTSL pursuant to Part 4A of the Act;

“the Returns” means the CCR-Complaints, CCR001 (Financial Data) and CCR002
(Volumes) returns for the period ended 31 May 2017, which FCTSL was due to
submit to the Authority by 12 July 2017;

“the suitability Threshold Condition” means the threshold condition stated at
parapgraph 2E of Schedule 6 to the Act;

“the Threshold Conditions” means the threshold conditions set out in Schedule 6 to
the Act;

“the Tribunal” means the Upper Tribunal (Tax and Chancery Chamber); and

“the Warning Notice” means the Warning Notice issued to FCTSL dated 27 June



On the basis of the facts and matters and conclusions described in the Warning
Notice issued to FCTSL and in the Decision Notice, it appears to the Authority that
FCTSL is failing to satisfy the suitability Threshold Condition, in that the Authority
is not satisfied that FCTSL is a fit and proper person having regard to all the
circumstances, including whether FCTSL managed its business in such a way as to
ensure that its affairs were conducted in a sound and prudent manner.

This is because FCTSL has failed to comply with the regulatory requirement to
submit the Returns. FCTSL has not been open and co-operative in all FCTSL’s
dealings with the Authority, in that it has failed to respond adequately to the
Authority's repeated requests for it to submit the Returns, and has thereby failed
to comply with Principle 11 of the Authority's Principles for Businesses and to satisfy
the Authority that it is ready, willing and organised to comply with the requirements
and standards of the regulatory system.

These failures, which are significant in the context of FCTSL’s suitability, lead the
Authority to conclude that FCTSL has failed to manage its business in such a way
as to ensure that its affairs are conducted in a sound and prudent manner, that it
is not a fit and proper person, and that it is therefore failing to satisfy the Threshold
Conditions in relation to the regulated activities for which FCTSL has had a


The decision which gave rise to the obligation to give this Final Notice was made
by the Regulatory Decisions Committee.


This Final Notice is given to FCTSL in accordance with section 390(1) of the Act.


The Authority must publish such information about the matter to which this Final
Notice relates as the Authority considers appropriate. The information may be
published in such manner as the Authority considers appropriate. However, the
Authority may not publish information if such publication would, in the opinion of
the Authority, be unfair to FCTSL or prejudicial to the interest of consumers.

The Authority intends to publish such information about the matter to which this
Final Notice relates as it considers appropriate.

Authority Contact

For more information concerning this matter generally, please contact Rachel
Fasanya at the Authority (direct line: 020 7066 3202).

Anna Couzens
Enforcement and Market Oversight Division


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