FIA on 25 September 2020 submitted a response to the FCA Discussion Paper on a new UK prudential regime for MiFID investment firms. The response focuses on a few specific proposed requirements that FIA UK-based investment firm members have identified as problematic or needing further clarification. These concerns include issues arising out of certain K-factors (K-CMG and K-DTF/K-COH), the proposed transition from existing IFPRU/BIPRU Individual Capital Guidance, the proposed level of application of ICARA process and the application of Group Capital Test. FIA and its members look forward to engaging with the FCA further on designing new prudential rules for UK investment firms.
