IFPR: the FCA’s first consultation paper explained (CP 20/24)

IFPR pillars

The FCA’s first consultation paper on IFPR – the new prudential regime for investment firms – was published last month. One of three planned CPs, this paper focuses on the areas the regulator feels will need the most preparation. Given the quantity and complexity of the new requirements we recommend planning for the regime as soon as possible.

If you thought one of the benefits of leaving the EU would be that the FCA’s publications would be shorter than the EBA’s tomes, you are going to be disappointed.

The paper on the new UK Investment Firm Prudential Regime (CP 20/24), which the FCA issued in mid-December, is over 300 pages long. The regulator’s approach is to stagger the topics on which they consult to allow firms to absorb and respond to proposals in a more manageable way. Two further papers are planned in the coming months. The deadline for responses to this first CP is 5th February.

The topics in this first paper include the following:

  1. Categorisation of small non-interconnected firms (SNI) and thresholds
  2. Consolidation and the group capital test
  3. Own funds resources and some aspects of the own funds requirement – permanent minimum capital and K-factors relevant to firms with a trading book, including transitional provisions
  4. Concentration risk
  5. Reporting

You can download our summary of what the FCA has proposed for each of the topics below.

And of course, you can always get in touch with our prudential team to discuss any aspect of the new IFPR regime in more detail.

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