UK investment firms subject to the FCA’s new IFPR regime will be well aware of the volume of notifications and applications that were and are required depending on individual circumstances.  A key notification – mandatory for all firms not previously subject to the CRR (e.g. former BIPRU and Exempt-CAD firms) – was the confusingly-named MIFIDPRU TP 7.4R(2)(b) notification.

The background is that the FCA needs to ensure all investment firms have capital which complies with the relevant criteria.  Due to the impracticality of the FCA approving the capital instruments held by all firms in scope of the IFPR, firms are required to self-certify that they meet the criteria.

Many firms missed the original deadline of 31 December 2021, as explained by the FCA in their quarterly consultation paper CP22/4.  As such the FCA have extended the deadline to 29 June 2022.  The FCA has been clear that firms which fail to submit the notification by this date will, thereafter, have no eligible capital instruments and could therefore be in breach of own funds requirements and non-compliant with Threshold Conditions, which is a serious problem.

Firms should therefore make absolutely sure that they have submitted the notification by 29 June 2022, if they were required to do so.  Contact Centralis Governance, Risk & Compliance for assistance with completing the notification and advice on how to ensure your firm has adequate financial resources in line with the regulator’s expectations.