IFPR: the FCA’s second consultation paper explained (CP 21/7)

The FCA’s second IFPR Consultation Paper (CP) was published in Q2 2021 as promised. This time the focus of the CP is on the ICARA (the risk-based document all firms need to prepare), governance, remuneration and the remaining K-factors not discussed in the first paper.

While the FCA has provided some guidance and headings on what they want firms to include in the ICARA, this is very high level and firms will still have to do a lot of the work and thinking on their own.

Our paper, based on an extensive review of the 450 page CP; breaks down the major considerations for firms spanning:

  • Own funds requirements and Fixed Overhead Requirement (FOR)
  • Firms acting as clearing members
  • Basic liquid assets requirement
  • Risk management (ICARA and SREP)
  • Governance
  • Remuneration
  • Regulatory reporting in areas not covered in the first CP