This document constitutes FIA EPTA’s response to the FCA’s Consultation Paper on a new UK prudential regime for MiFID investment firms (CP20/24). We very much welcome the FCA’s approach as set out in the Consultation Paper and generally agree that the FCA’s proposed rules are clear, proportionate and fit for purpose. In our response, we focus on a number of key areas where we believe further improvements or clarifications could be made to enable a proportionate, effective and practicable prudential regime for investment firms. FIA EPTA members appreciate the FCA’s consideration of our comments and suggested solutions and stand ready to provide any further input as required.
