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

CRD IV for Investment Firms
CP13/6
Figure 1: CRD IV – Overall outcome for investment firms
(Illustrative only - simplified and not intended to show relative impacts; EU text and FCA
consultation proposals must be read for actual requirements that may apply)
2013
More requirements
1 Jan
2014
CRD IV (CRR + CRD + BTS)
By end
2015
Current CRD (BCD + CAD)
€730k; €125k
(& some
€50k*) firms
Status quo Most €50k
firms* that
execute orders
and/or manage
portfolios
Current Exempt - CAD
CA discretion
to apply CRD3
under national
rules
Various
technical
derogations
(pending
review)
But...
Risk-based
capital test
under
CRD IV
rules
Investment Firm Reviews
(liquidity + whole regime
+ commodity derivative firms)
Less requirements
Full-exempt CAD firms: Advice and/or
reception & transmission or orders
*Note: actual situation will depend upon precise investment services and activities consucted under MiFID
Full implementation of all of CRD IV (& expiry of transitional provisions) by January 2019
Summary of key derogations in the CRR and in the Directive by type of firm
2.7 This section provides details of key derogations in the CRR and in the Directive by type of firms.
2.8 At present, the different categories of firms subject to CRD are set out in BIPRU 1.1 with further
guidance on the categorisation of investment firms in Chapter 13 of the Perimeter Guidance.
In this section, the relevant firms are: ‘full scope BIPRU investment firm’, ‘BIPRU limited activity
firm’, and ‘BIPRU limited licence firm’.
2.9 As outlined in Chapter 1, under CRD IV we are creating a new ‘Prudential Sourcebook for
Investment Firms’ (IFPRU), but we have minimised as much as possible changes to the names
of the prudential categories (e.g. we have kept the structure replacing ‘BIPRU’ with ‘IFPRU’) in
line with our overall approach. We have also created a new prudential category called ‘BIPRU
firms’ for certain firms that only execute orders and/or manage portfolios, without holding
client money or assets (see Chapter 6).
Financial Conduct Authority July 2013
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