There’s a limited amount the FCA can say at this time.
The Brexit negotiations with the EU and the responses from the various interested governments, all with a different political axe to grind, make it exceedingly difficult for the FCA to produce definitive statements. In general terms, the FCA say what is going to happen, there is some tweaking around the edges, and we all get on with it, whether we like it or not.
This time round, a lot of us are relying on the Temporary Transitional Power to keep things going, a stopgap until there is a clearer way forward. Unfortunately, most regulated firms have some area that will need to change from day one. With day one now only 16 days away, the majority of staff working from home and Christmas coming up fast, perhaps now is the time to take one final look over your preparations.
FCA Key Requirements
The FCA have sent out a reminder about the key requirements that must be in place from 1st January. This contains a link to the document issued back in October detailing those areas where the Temporary Transitional Power does not apply. A link to that FCA page can be followed by clicking here.
There are too many to list in this short article, but suffice it to say, there’s probably something that affects most firms, whether it be transaction reporting, CASS rules, payment services, or the use of credit ratings.
A none too subtle warning is attached within the FCA press release, prompting firms to make sure that the correct permissions are in place to service your customers after the end on passporting. The ‘right outcomes’ for customers after this time will probably feature in forthcoming visits, whether physical or virtual.
The FCA will lose access to two of the European Securities and Markets Authority (ESMA) systems at the end of the year, and they have notified all firms that the replacement service will be up and running from 2 January.
Unfortunately, the test systems for FCA FITRS and FCA FIRDS will be switched off from the 16th December, so if some staff still need to get up to speed on the changes, time is running out.
The final countdown.
Time is short and what preparations you can make should have been implemented by now. With a dire Christmas TV schedule, and the possibility for sudden changes of direction in the last few days of 2020, you can have some yuletide fun and cheer by keeping on top of the Brexit news and how it will affect your firm.
As always, the good people at FSTP are here to help. Support and information can always be received from your regular contact or by contacting us here today.