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IFPR: The Final Consultation Paper CP21/26

The FCA released the 3rd and final IFPR Consultation Paper CP21/26 on Friday. The main focus of the paper is on disclosures in areas such as:

  • risk management

  • governance arrangements

  • own funds & own funds requirements and

  • remuneration.

Disclosures in these areas will be familiar territory for BIPRU & IFPRU firms through their annual Pillar 3 report but will be new for firms that are currently classed as Exempt CAD. There are reduced requirements for small non-interconnected firms (SNI’s).

While the concept of proportionality for disclosure will remain in force, there are more detailed requirements than the existing Pillar 3 requirements. For example, it is proposed that there is a template for disclosing own funds, to allow for consistency when comparing firms. New disclosures on the diversity policy of the management body include setting out the diversity targets and the extent to which those have been met.

Other areas included within the consultation relate to the capital requirements of depositaries, the treatment of excess drawings in partnerships and the onshoring of certain technical standards.

The CP can be found here: The consultation closes on the 17th September 2021.


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