8.28 In CP16/22, the PRA proposed that access to the ICR would be via a modification by consent.

8.29 While they welcomed the ICR, three respondents wanted clarification on this opt-in process, particularly with regards to the timeline for accessing the ICR.

8.30 Firms were unclear as to whether they could later exit the ICR with three respondents thinking that opting into the ICR may irrevocably commit a firm to the SDDT regime. One respondent also questioned how the ICR would accommodate a firm that ceases to meet the SDDT criteria during the period the ICR is in place.