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.
Dear CEO General Insurance Intermediaries Client Money Arrangements
Michael Senior Compliance FCA, protected, protection, transfer
Following a series of financial resilience surveys and a letter issued in September last year the FCA has issued a Dear CEO letter about adequate client money arrangements, that can be accessed here. The FCA is keen to ensure client money is adequately protected, that firms follow the CASS 5 rules and review arrangement […]