At the time of the changeover from OFT to FCA, the FCA granted all transferring companies interim permissions under which they could operate taking into account the new rules and regulations. At that time you will have also been given a window of three months by which it would want to receive your completed application. If you didn’t apply within that window, your application is classed as lapsed. Your interim permission is immediately withdrawn and you have no permissions to carry out regulated business.