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 Transfers – considering a workplace pension
Alistair MacDougall Compliance Defined Benefit, FCA, Pension, Pension Transfer, PI, Switch, transfer
We recently reviewed a pension transfer report where the client was recommended to transfer out of the defined benefit scheme into the client’s pre-existing SIPP. We considered that the recommendation to transfer appeared to be appropriate. However, the client had what the FCA calls an ‘available qualifying scheme’, more commonly referred to as a […]