With the second of the FCA's Investment Firm Prudential Regime (IFPR) consultations expected soon, now is a great time to take stock of your preparations for the new regime.
Unlike typical policy formation, the IFPR rules are being consulted on in three distinct ‘thirds’, rather than iteratively. This means rules from the first consultation are not likely to materially differ in subsequent consultations. It is therefore very important to keep on top of each consultation to allow maximum time for the next set of rules as they emerge.
With the overall UK deadline just nine months away, and a three-month deadline for anyone with European entities, firms cannot afford to wait for the full suite of consultations before starting work.
Where are firms in the IFPR process?
The types of firms covered by the rules are very broad and we're seeing varying levels of engagement depending on firm type. The first consultation included rules relating to own funds, some of the more complex k-factor
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