Guidance series from Japan Asset Management Platform Group (JAMP) will now explain, over the next few columns, what to prepare for financial instruments business operators (FIBOs) registration. First up is the “Summary of Applicant”, an applicant profile.

Summary of Applicant (the Summary) is required by the authorities as a tool for smoothly conducting dialogue between applicants and their Local Finance Bureaus.  As for investment management business, the official name is “Summary of Applicant for New Registration or its Change”, and the form is available for download on the official web site of the Financial Services Agency.


The Summary covers a wide range of items.  The primary items are:
1) Company overview;
2) Business operations;
3) Description and methods of business;
4) Internal control systems;
5) Complaint processing measures and dispute resolution measures related to financial ADR;
6) Types of other businesses you conduct;
7) Financial condition; and
8) Special notes (such as changes in officers);
followed by a separate questionnaire containing a large number of questions related to supervisory focus points indicated in comprehensive guidelines for FIBOs.

Additionally, you are required as needed to submit scheme diagrams, business plans (income and expenditure), and other related materials in order to certify employment status of human resources with sufficient FIEA (Financial Instruments and Exchanges Act) knowledge and experience is secured, planned business execution system and such.

Therefore, it is important to firm up your business model and to prepare a through business plan covering what intentions the company has on entering the financial instruments business, what kind of products and services the company intends to provide to what kind of investors, what kind of human resources the company will need, and what kind of internal control system it will establish.

Finally, it is essential to understand the provision of FIEA, at least those necessary for your business, in order to communicate smoothly with the authorities.