Interesting point Billiebob. It would be interesting to see if someone has gone through the process.
There’s always a get out for the authorities as it states they (competent authority) may issue a certificate and that the FI complies with the requirements within the subpart.
It would be interesting to see what the CAA would require to fulfill this requirement?🤔 Probably sit all the CPL exams and carry out a full FI course!