Following a consultation process begun in October 2022 (see our earlier blog post here) the FCA has published a policy statement (PS22/3) in relation to the new financial resilience regulatory return for solo-regulated firms.
The new return will be known as ‘FIN073 – Baseline Financial Resilience Report’ and in-scope firms will need to be prepared to submit the return when it is due, from January 2024. Firms will receive an automated reminder via RegData when the return is available for submission.
The FCA's proposals are largely unchanged since the consultation paper, with the FCA affirming that collecting data on a quarterly basis provides the right balance between utility of the data and frequency of reporting. The FCA also highlights one of the main benefits of FIN073 as providing baseline liquidity information which the FCA does not get through other regulatory returns such as RMAR.
The policy statement, including feedback on responses to the consultation and final rules, applies to a wide range of firms with some significant exceptions, including MIFIDPRU investment firms for which the FCA already receives a full set of baseline financial resilience data. The rules will also apply to authorised and small electronic institutions, authorised and small payment institutions, registered account information service providers and UK RIEs.
While the FCA deems the scope of FIN073 to be proportionate, it has also published a consultation paper (CP23/9) covering a proposal to exclude firms with limited permission and bring all full permission consumer credit firms within scope. The FCA has requested comments on this proposal by 6 June 2023, following which the FCA will consider any feedback and publish a statement in Summer 2023.