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

CP13/6
CRD IV for Investment Firms
Q7: Until such point as we are able to consult further on
our future policy, do you agree that the CPB should be
maintained and added to the Pillar 2A charge to the
extent that there is no identifiable double counting?
If not, please explain why not including alternative
transition approaches and the rationale for those
approaches.
Q8: Do you agree with our proposed approach on stress
testing and to report results annually in the case of
those firms that are ‘significant’ pending the EBA
guidelines on this matter? If not, please explain why not
and propose alternative approaches and the rationale
for those approaches.
Q9: Do you agree with our proposal to continue the UK’s
liquidity regime (including ILAS) until binding minimum
standards for liquidity coverage requirements are
implemented in the CRR in 2015? If not, please explain
why not and propose alternative approaches and the
rationale for those approaches.
Q10: In your view, is this approach proportional and risk
based? If not, which category or categories of firms
(within the solely FCA regulated CRD IV population) do
you perceive as appropriate to submit CRD IV liquidity
reporting forms from 2014 and be subject to binding
liquidity requirements from 2015?
Q11: Do you agree that these proposals meet our approach of
applying the transitional provisions whilst ensuring that
we do not materially reduce the standards of the current
FCA framework? If not, please indicate why not stating
your reasons and your alternative proposal.
Q12: If appropriate, please can you provide a list of all
capital instruments used by partnerships and LLPs
that, in your opinion, satisfy the criteria outlined in
article 28 of the CRR?
Q13: Considering the legal constraints in respect of EU
regulation and in the context of internal models, do you
agree to our proposal to use guidance where appropriate
while explaining the operational implications of the
changes via targeted communications? If not, please
explain why not and propose alternative approaches and
the rationale for those approaches.
Q14: Do you agree with our approach to these exemptions? If
not, which exemptions under Article 400(2) of the CRR do
you believe should be included, or should not be included,
which is contrary to the proposed amendments?
92 July 2013
Financial Conduct Authority