Regulatory reminder: new disclosure requirements under IFPR
The Investment Firm Prudential Regime (IFPR) has introduced new Public Disclosures requirements for investment firms, replacing the Pillar 3 disclosure obligations under previous regimes. Not only do firms have to disclose more than before, the disclosures are now applicable to all MIFIDPRU investment firms, including previous exempt-CAD firms.
While there were transitional provisions available during the first-year post implementation of the IFPR for accounting reference dates from 31 December 2022 onwards, the full requirements are now applicable, so it is vital that firms report and make disclosures accurately and on time to meet the FCA’s requirements. As part of the ‘transformation’ agenda of the FCA, if firms do not meet the deadline or disclose the correct information that is required of them, they are likely to attract unwarranted attention from the FCA which may lead to closer scrutiny.
The publication of the Disclosures is an annual process which is intended to highlight risk and remuneration policies and practices of a firm, which must be made publicly available when the firm’s annual financial statements are published. The information that must be publicly disclosed will depend on the size, scale, and complexity of the firm, and some firms may have to disclosure information regarding governance, risk management and own funds resources. Firms may still be unclear as to the extent of information they must disclose.
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