The FCA has published its first consultation paper on the new Investment Firm Prudential Regime. The consultation paper covers categorisation, consolidation, capital resources and requirements, concentration risk and regulatory reporting.

Initial impressions show few material deviations from the discussion paper published back in June, but:

– all firms can now expect a quarterly reporting obligation (i.e. no annual carve out for small firms) on a single suite of reporting templates; and

– for adviser-arranger firms, transitional provision for capital requirements are proposed to be a smoother but faster increase over the 5-year period.

Subsequent consultation papers are expected to cover the ICARA process, governance, risk, remuneration and disclosure, but one consideration that is flagged is that consolidated ICARA process back on the agenda for investment firm groups.

The consultation paper poses 23 questions to investment firms and the consultation closes on 5 February 2021. Investment firms are encouraged to to review and, where appropriate, respond to the consultation paper. Watch this space for further updates from Wheelhouse Advisors Limited.