CP13/6 - CRD IV for Investment Firms - Financial Conduct Authority

CRD IV for Investment Firms
CP13/6
Approach to cost benefit analysis
1.28 The CBA in Annex 1 analyses the overall incremental impact of CRD IV in terms of its effects
on firms and markets. As set out in this CP, our proposals do not cover new or changed
requirements now in CRR that apply directly as regulations and thus require no transposition
through national rules or guidance. However, the impact of these regulations on firms and
markets will in many cases be difficult to differentiate from the impacts of changed requirements
arising from transposition. Therefore, the CBA considers the impacts of the overall package of
CRD IV when assessing costs and benefits, and thus presents analysis of impacts arising from
the mainly non-optional changes to regulations.
1.29 The most significant impacts are likely to arise due to new regulations and transposition of the
Directive. Incremental costs and benefits arising from ‘optional’ exercise of national discretions
and derogations are likely to be small relative to these other impacts and we may not be able
to differentiate them from the overall impact of the Directive.
1.30 Where they are significant, the impacts of such discretions or individual regulatory changes
arising from transposition are analysed briefly in the main body of the CP. We anticipate that
many of the discretions will have only marginal impacts.
Equality and diversity considerations
1.31 We have assessed the likely equality and diversity impacts of the proposals and our assessment
concluded that they do not give rise to any concerns. But we would welcome your comments.
Next steps
What do you need to do next?
1.32 Please send us your comments and/or responses to the questions on our proposals by 30
September 2013 when the consultation will close.
What will we do?
1.33 We will consider your feedback and publish a Policy Statement later in 2013 so firms have the
final rules available before 1 January 2014.
1.34 We may need to consult further on issues linked to the Treasury or following subsequent
guidelines and/or technical standards from the EBA (to the extent permitted by EU law). For this
purpose, we may include in the Policy Statement some of these items for a short consultation.
1.35 Our proposals in this CP will trigger consequential changes to many parts of the FCA
Handbook. Most of these are relatively minor, for example, amending cross references between
sourcebooks. Although we intend to include part of the consequential changes in this CP, there
may be a need to consult on some of them at a later stage either through a quarterly CP or by
other means; we will give further information on timing in due course.
Financial Conduct Authority July 2013
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