Nothing major, but take note.
The FCA has announced that it will be replacing the Financial Resilience Survey with a new financial resilience regulatory return. This will be referred to as ‘FIN073 – Baseline Financial Resilience Report’.
Firms still need to complete the Financial Resilience Survey when requested to do so until the new return comes into force in January 2024
This applies to all FCA regulated firms except:
- Credit brokers
- MIFIDPRU investment firms
- Not-for-profit debt advice bodies
- PRA-authorised persons
- Supervised run-off firms
- Temporary Permission (TP) firms
The changes also apply to:
- Authorised electronic money institutions
- Authorised payment institutions
- Registered account information service providers
- Small electronic money institutions
- Small payment institution
- UK Recognised Investment Exchanges
Firms that will be brought into scope of FIN073 will receive an automated reminder via RegData and need to be prepared to submit the return when it is due, from January 2024.
FCA is also consulting simultaneously on changing the scope of FIN073 to include full permission consumer credit firms. These firms are currently excluded from the rules considering that they are captured under the definition of Credit Brokers.
Following the closure of CP23/9 in June 2023 FCA will publish its final position.
Pension Transfer charging
Alistair MacDougall Compliance abridged, FCA, P1, Pension, Pension Transfer, PI, transfer
Policy Statement PS 20-06 stated that a firm providing pension transfer advice “… may also not charge less than it would charge for investment advice of the same value”. That seems clear enough, but the rule that gives effect to this statement is subtly different. COBS 19.1B.7 states: “A firm should not charge less […]