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22 December 2021 

Calling all FCA investment firms! Don’t forget you must meet the two notification deadlines coming soon under MIFIDPRU 3.

We are urging all advisers who find themselves inside the new prudential regime to review the regulations and ensure you understand your obligations.

On January 1, firms and their parent undertakings, who have not been subject to the UK CRR definition of capital (currently categorised as BIPRU, exempt CAD, local firms and exempt commodities firms), must notify the FCA if you wish to count pre-MIFIDPRU capital instruments as own funds. (As set out in the MIFIDPRU TP 7.4R notification.)

Unregulated parent entities needing to submit the TP 7.4R notification, who do not currently have access to Connect, should complete the following form: mifidpru notification tp-7-4r2b.docx and return it to ifprquery@fca.org.uk as soon as possible. The FCA expects the notification to be approved by a director registered at Companies House, or by someone who holds a similarly senior position.

B-Compliant director, Vicky Pearce, said: “Time is running out for firms who are not yet familiar with the list of MIFIDPRU notifications and relevant permissions. In respect of the capital instruments deadline, you need to meet the conditions set out by IFPR and notify the FCA in good time if you want to avoid applying for a separate permission.”

By February 1, all firms and their parent undertakings, who have been subject to the UK CRR and hold instruments, which satisfied the conditions to be classified as additional tier 1 (AT1) instruments, must notify the FCA of the intended treatment of these instruments. (As set out in the MIFIDPRU TP 1.8R notification).

Vicky added: “Notifications under MIFIDPRU TP 7.4R and TP 1.8R can be made through Connect and should not take long to complete. However, we know there are firms who are yet to get to grips with IFPR and will struggle to meet these initial deadlines. I would urge anyone who remains unsure of their obligations to reach out for professional help, before you put your firm at risk of FCA sanctions.”

To find out more about preparing for the IFPR deadlines, or any part of the regulations, don’t hesitate to contact us on (0161) 521 8641 or take a look at our overview here.

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