We thought it would be prudent to send one final reminder regarding the change to the Capital Resource Requirements that come into force 31/12/13.
The new capital requirements under IPRU for Personal Investment Firms (PIF’s) to be implemented over a three year period are:
| Deadline | EBR | Minimum Requirement |
| 31 December 2013 | 1 month (4 weeks) | £15,000 |
| 31 December 2014 | 2 months (8 weeks) | £15,000 |
| 31 December 2015 | 3 months (13 weeks) | £20,000 |
EBR is your ‘Expenditure Based Requirement’ i.e. the amount of fixed expenditure you need to hold as capital. The calculation is not straightforward so please speak to your ATEB consultant if you are unsure.
Note the changes affect all firms giving investment advice, those of you that only advise on mortgage and insurance business will still be governed by the MIPRU rules that are not changing.
If you have subordinated loans then refer to your ATEB consultant for clarification how these are treated.
Identify, Assess & Manage
Steve Bailey Compliance FCA
Before you read on, what do you think the title refers to? The answer is Business Risks. The FCA has been highlighting this issue in workshops. They expect firms to ‘Identify, Assess & Manage’ risks and to be able to provide documentary proof that they are so doing. They expect firms to have at least […]