2017年-FCA英国金融行为监管局_reform_of_legacy_credit_union_sourcebook_3页_139kb

Summary of Regulator Assessment: Qualifying Regulatory Provisions

Title of Proposal

Reform of the legacy Credit Unions Sourcebook

Lead Regulator

• CP15/21: Prudential Regulation Authority (PRA), with the Financial Conduct Authority (FCA) making consequential amendments.
• CP14/31: Financial Conduct Authority (FCA)

Date of Assessment

25 July 2016

Commencement Date

• CP15/21: 3 February 2016
• CP14/31: 7 March 2016

Origin

Domestic

Impact of Cutting Red Tape Review

No

Areas Affected

All areas of the UK

Brief Outline of Proposed Regulatory Activity

The Credit Unions Sourcebook (CREDS) was originally a joint sourcebook before the FSA split into the PRA and FCA. The reform of CREDS was part of a broader effort to align the regulatory frameworks of the FCA and PRA.

Key Changes in CP15/21:

• Reform of CREDS: The FCA proposed minimal changes to its rules for credit unions, primarily to remove non-relevant rules and guidance, thereby avoiding duplication with the PRA's new Credit Union Rulebook.
• Clarification of FCA Responsibilities: Focus on the conduct of business by credit unions.
• Alignment with PRA Rulebook: Changes to senior management arrangements and systems and controls to match the PRA's framework.
• Regulatory Reporting Adjustments: Modifications to reporting arrangements to aid FCA supervision.
• Oversight Corrections: Addressing outdated links, omissions, and references to PRA-only rules in CREDS.

Key Changes in CP14/31:

• Senior Managers and Certification Regime (SM&CR): Policy changes related to transitional arrangements for individuals moving from the Approved Persons Regime to SM&CR, introduction of new forms for reporting and applications, and minor consequential amendments to the FCA Handbook.
• Impact on Credit Unions: These changes affected individuals working in credit unions, particularly in relation to senior management roles.

Business Impact

Affected Businesses

• All credit unions in the UK: Approximately 500 firms.

Costs and Benefits for CP15/21

• Costs:
  1. Increased expectations on governing bodies to review policies and procedures (already required due to PRA changes).
  2. Submission of two sets of accounts (to FCA and PRA) instead of one, requiring an additional email address.
  3. Updating compliance and policies manuals to reflect changes, which is already necessary due to PRA reforms.
• Benefits:
  • Improved compatibility between FCA and PRA rules for credit unions.
  • Streamlined regulatory framework for better supervision and compliance.

Estimated Net Cost: 0 (considered minimal and not quantified in detail).

Costs and Benefits for CP14/31

• No direct costs or benefits are included in the amendments published in PS16/1, as they are consequential to changes in previous consultations (CP15/22 and PS15/21).

Additional Information

• PS16/1 includes both changes from CP15/21 and consequential changes from CP14/31.
• BIT Score: 0 for both CP15/21 and CP14/31.
• Cost Benefit Analysis: Not conducted for CP15/21 due to the minimal nature of the changes.
• Policy Documents:
  • Policy Statement 16/1
  • Consultation Paper 15/21
  • Consultation Paper 14/31

Key Takeaways

• The reform of CREDS is part of a broader effort to align the FCA and PRA regulatory frameworks.
• The FCA's changes are minimal and do not impose new significant obligations on credit unions.
• The PRA made more substantial changes, including the creation of a new Credit Union Rulebook.
• The impact of these changes is considered negligible in terms of cost, with the main benefit being regulatory consistency.
• These changes are expected to be implemented indefinitely.