Have you responded to the FCA's IFPR Questionnaire?

The FCA has been sending out requests to Investment Firms asking them to provide responses to the FCA's Investment Firms Prudential Regime (IFPR) Questionnaire, ahead of IFPR implementation on 1 January 2022. Responses are typically required to be made within a few weeks of the request. Have you responded?

The Investment Firms Prudential Regime (IFPR)

On 1 January 2022, the FCA's IFPR will come into force in the UK. The new regime is designed to simplify the prudential requirements for MiFID investment firms prudentially regulated by the FCA. The IFPR introduces a new capital requirements methodology, as well as new reporting, disclosure and remuneration rules. The new rules will largely be contained in the FCA's new MIFIDPRU sourcebook.

Who does the IFPR apply to?

The IFPR will apply to the following types of firm:

  • MiFID investment firms authorised and regulated by the FCA;
  • Collective Portfolio Management Investment Firms; and
  • Regulated or unregulated holding companies of groups that contain either of the above types of firm.

The IFPR will not apply to PRA-designated investment firms.

Transitional arrangements are available for certain types of firm, which will delay the application of parts of the regime.

The FCA's IFPR Questionnaire

Ahead of the 1 January 2022 implementation date, investment firms are being asked to fill in a Questionnaire, which includes questions relating to the firm’s status as a small and non-interconnected FCA investment firm (SNI), investment firms' corporate structures and their expected ICARA reporting dates.

This can raise complex questions for firms, particularly in relation to the application of IFPR on a consolidated basis to investment firm groups and the steps that it may be possible to take to mitigate the impact of the IFPR on your group’s capital requirements.

Next Steps

We have been advising on these matters for several clients. If you would like assistance with completing your IFPR Questionnaire, or on steps that may be taken to mitigate the impact on your capital framework, please get in touch with any of the contacts listed.

Please also get in touch if you would like advice on your implementation of the IFPR requirements from 1 January 2022.

 

Authored by Anahita Patwardhan and Michael Thomas.

 

Contacts
Michael Thomas
Partner
London
Anahita Patwardhan
Senior Associate
London
Dominic Hill
Consultant
London
Richard Barfield
Consultant
London

 

This website is operated by Hogan Lovells Solutions Limited, whose registered office is at 21 Holborn Viaduct, London, United Kingdom, EC1A 2DY. Hogan Lovells Solutions Limited is a wholly-owned subsidiary of Hogan Lovells International LLP but is not itself a law firm. For further details of Hogan Lovells Solutions Limited and the international legal practice that comprises Hogan Lovells International LLP, Hogan Lovells US LLP and their affiliated businesses ("Hogan Lovells"), please see our Legal Notices page. © 2022 Hogan Lovells.

Attorney advertising. Prior results do not guarantee a similar outcome.