As of 1 June, the FCA will no longer be accepting the old change of legal status application (COLS). So if you are looking to change the legal entity type of a regulated entity in your group, you will no longer be able to use the 'COLS' route to effectively transfer the relevant permissions.

Rather, 'if you are thinking of changing your firm’s legal status, you will need to submit a New Authorisation application'.

'When submitting a new application for the new legal entity, you will need to sign a Deed Poll declaration. This requires your firm to deal with any complaints from existing customers in the same way that it would customers of your new legal entity. The FCA have this requirement to prevent firms leaving behind their obligations to their customers by changing their legal entity. Before your application is approved, the FCA will ask you to cancel the previous entity's permissions.'

This change comes as the FCA, following a review, found that it is more efficient for firms to submit new applications in this scenario.

The latest change of legal status FCA page can be found here.