In general, the FCA has implemented its proposals as consulted on but it has provided further clarity in several areas, including:
- the firms that MIFIDPRU will apply to
- how/which MiFID activities determine a firm’s classification as either small and non-interconnected firms or not
- the interaction between IFPR and the UK Capital Requirements Regulation
- the treatment of tied agents and appointed representatives
- the definition of own funds and the items that should be deducted for CET1 purposes
- calculation of K-factor requirements
Accompanying the PS are the near final rules and the FCA does not expect to make any changes to these rules before they are made final.
The FCA will publish a further consultation paper this year and two further policy statements summarising the feedback received and bringing together the final rules.