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.
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 […]