How to start completing an application
Whether you are using OneComply or not, you still need to gather the necessary information. This is sometimes the hardest part. Here are some tips that may help you get through this process a little bit easier.
Create a baseline
Are you going to one jurisdiction in the next year, or three? At the end of the process 99% of the information that is being requested will be the same, but maybe not on the same timeline. For example, New Jersey is light on the amount of documentation that is requested on your application submission. Just because they do not ask for three years of bank statements does not mean they don’t want it, they just don’t want it now. If you are going to Illinois, they want it ALL upfront.
It is better to start keeping track of what every jurisdiction is going to want so you can create a baseline of information you need to start gathering. There is nothing worse than doing a bunch of digging for information only to have the next application you fill out requesting an extra year or two of data that you could have gotten earlier.
Read the directions
Regulators understand they are asking a lot. Because of this, they do provide instructions on what you need to do to submit a completed application. This will only help you as you digest the process you are about to partake in.
Read the definitions
These are not from Webster’s. These definitions are created at the discretion of the regulator and each regulator defines things a bit differently.
Pay attention to the following key terms:
- Family members
- Substantial Ownership
- Key Person
Understanding these terms will help you provide an accurate submission based on regulators preference.
Ask for help
This is not a test. Regulators want honest and transparent answers. They want you to complete this correctly as it means fewer questions and headaches for the investigators.
Using legal counsel is never a bad idea.
This one may be hard to believe but, ask the regulator! Every regulator has staff that just field questions to help applicants better understand what is actually being requested. Don’t understand the difference between a fiduciary officer and fiduciary position, ask them.
Try doing exactly what the regulator is going to do. They are going to audit the information provided to see if it makes sense. Did you write that you had a job in Detroit, but your residential history says you’ve never lived in Michigan? Own a house in the residential section but nothing under real estate in your net worth statement? Investigators are trying to connect you, family, business, assets, and financials to see if everything fits.
Another tip is to run a background check on yourself. The regulator will. See what comes up. Maybe there was a bank account that you never closed that shows up. A small civil suit from ten years ago you forgot about. Our Partners at CERTN do a great job of giving you insight into what the regulators will see.
You have everything together and think it is ready to go. Do one last review. Is everything uniform, and spelled correctly? Is it clean and presentable? You are going to be judged on this application, and appearance counts. The neater and easier your application is to review is only going to benefit you. This means less clarifying questions and less frustration from the investigator. That is a good thing.
You have printed, signed, collated, and finally gotten the ink from fingerprinting to wear away. Your application is out the door. Unfortunately, you are not done. You will be getting, hopefully, some good news that your application has been received. Then a notification that you are allowed to conduct business while the regulatory body conducts their investigation, which can take up to two years. During that time you will receive a letter stating that the regulator is requesting even more documents. This is where that baseline comes into play.
At this point the investigator will start requesting items that you did not see on the application. Marriage licenses, birth certificates, loan documents, titles, insurance, and a delta of the time passed for the documents you submitted with your original application.
This is why creating good habits that constantly maintain your records is very important. Every bank statement should now be collected and stored because you will need it again. Make it easier on yourself. Make a move, have a child, buy a house, these are all actions that create documentation that is not only needed for applications and investigation, but it is also very important for yourself.
For Business Submissions
Do everything stated above!