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UK FCA issues clarification on IFPR and SM&CR

22 August 2022

The UK Financial Conduct Authority (“FCA”) has issued an update and clarification to the market in respect of the Investment Firm Prudential Regime (“IFPR”) and its impact on the Senior Management & Certification Regime (“SM&CR”).

When the IFPR was introduced in January 2022, it was renamed and moved the definition of ‘significant IFPRU firm’ used as one of the criteria for identifying Enhanced Firms under the SM&CR. This was to retain the definition in the FCA’s rules following deletion of the IFPRU sourcebook.

As a consequence, a number of stakeholders may have found that this new definition of ‘Significant SYSC firm’ could have resulted in more firms being brought into Enhanced scope than under the previous definition as it had been understood and applied.

The FCA plans to consult shortly to make changes necessary to clarify that only firms that would have been both Significant IFPRU firms and IFPRU investment firms under the pre-IFPR arrangements fall within the new definition of ’Significant SYSC firm’ for the purposes of the Enhanced Scope SM&CR regime.


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