Requires that Paragon’s business model (i.e. strategy) be suitable for a regulated person carrying on the regulated activities that Paragon carries, or intends to carry on. A number of factors are relevant to this suitability assessment, including:

• whether the model is compatible with Paragon’s affairs being conducted, and continuing to be conducted, in a sound and prudent manner;
• the interests of consumers; and
• the integrity of the UK financial system.

The FCA pays particular attention to the distribution business model employed by Paragon, in particular the implementation, use and management of systems, controls and consequential management information.

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