In quarterly CP No. 37 (CP22/26), the FCA has proposed to make some amendments to MIFIDPRU to provide further clarification on the new IFPR requirements, and to amend the Glossary, SYSC, COND, IPRU-INV and SUP to rectify some errors that have been identified, and to provide further clarification.

These changes include:

• Amending the definitions of "qualifying holding", "non-core liquid asset", "own funds wind-down trigger" and "consolidated situation";
• Making certain changes to the MIFIDPRU remuneration code and SMCR allocation of prescribed responsibilities;
• Making various amendments and corrections to MIFIDPRU 1, 2, 3, 4, 6, 7, 9 and the transitional provisions in MIFIDPRU TP;
• Amendments to the integrated regulated reporting rules in SUP 16.

Although the FCA considers these minor enough changes to be consulted on through the quarterly consultation process, they could impact how MiFID investment firms and (where relevant) their UK parents have applied MIFIDPRU to their firm and/or group, particularly given the highly technical nature of the rules (where apparently small details can make a material impact on how the rules bite). Firms should therefore look closely at the proposal and seek advice where necessary. 

Feedback on the FCA's proposals is invited within five weeks; by 9th January 2023.