The FCA has published a Discussion Paper on the implementation of the new prudential regime for investment firms.

Coupled with the consultation papers and roadmap published by the EBA earlier this month, the pieces of the puzzle are beginning to come together as to how the regime will affect European investment firms.

The paper seeks to explain and discuss how the regime will be applied in the UK post-Brexit, noting the intention to “achieve similar intended outcomes as the IFD/IFR whilst taking into consideration the specifics of the UK market”.

Perhaps the area of most interest from UK investment firms will be around the ICARA process (the new, enhanced ICAAP). The EU Directive spoke of a possible exemption for small non-interconnected firms but the FCA believes all firms should apply the principles proportionately. We could see ICARA process rules for all investment firms… watch this space.

To discuss this further email our Head of Prudential, Mike Chambers mchambers@wheelhouse-advisors.com