2017年-FCA英国金融行为监管局_handbook_notice_28_supervision_manual_2页_166kb

Regulator Assessment Summary: Qualifying Regulatory Provisions

Core Content

This document provides an assessment of the regulatory changes introduced in Handbook Notice 28 - Supervision Manual (Amendment No 21) Instrument 2015, which focuses solely on changes related to the Regulatory and Reporting Manual - Client Money (RMA-C). The assessment was conducted by the Financial Conduct Authority (FCA) on 12 October 2016, with the changes coming into effect on 31 March 2016. The regulation is domestic in origin and does not include the implementation of a Cutting Red Tape review.

Affected Areas and Businesses

The regulatory changes affect UK-authorised firms that engage in insurance mediation activities and are required to submit client money holdings to the FCA via the RMA-C return. These firms are expected to hold and report client money in accordance with the Client Assets Source (CASS) rules.

Estimated Number of Affected Firms

• Approximately 1,500 firms are impacted by the changes.

Regulatory Changes Overview

The changes to the RMA-C were aimed at improving the accuracy and usefulness of the data collected on client money holdings. Specifically, the following adjustments were made:

• Removal of 3 questions related to retail investments and mortgages, as the data for these areas was already obtained through other FCA returns.
• Amendment of 10 existing questions to better align them with the CASS rules.
• Addition of 5 new questions related to the CASS audit report.

These changes were consulted on in FCA Consultation Paper 15/28 and were finalized for implementation on 31 March 2016.

Impact on Business

Cost and Benefit Breakdown

• No new information gathering was required from firms, as the data they needed to report was already in-house.
• One-off costs were considered, such as familiarisation and adjusting data collection systems, but these were deemed negligible.
• No material ongoing costs were expected, as firms already had the necessary resources to submit the RMA-C return.
• Cost savings were identified through the removal of redundant questions, reducing the reporting burden.

Overall Assessment

• The cost-benefit analysis concluded that the changes would have minimal significance.
• No respondents during the consultation or following the publication of the final rules challenged this conclusion.
• For the purposes of this impact assessment, incremental compliance costs and cost savings are considered to be zero (i.e., below £100k in aggregate).

Additional Information

• No additional information was provided that would assist the Regulatory Policy Committee (RPC) in validating the BIT score.

Key Takeaways

• The changes to the RMA-C are minimal in terms of compliance burden and cost.
• Firms were not required to collect new data, only to reformat existing data to align with the CASS rules.
• The assessment concludes that the changes do not impose significant costs or benefits on the affected firms.