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

CP13/6
CRD IV for Investment Firms
Q24: Do you agree with our proposal to define a firm as
a ‘significant’ firm if it exceeds at least one of these
thresholds? If not, please explain why not and propose
alternative approaches and the rationale for those
approaches.
Q25: Do you agree to our proposal to exercise the discretion
in article 95(2) of the CRR to retain current CRD rules
in force on own funds requirements (Pillar 1) for BIPRU
firms keeping the ‘status quo’ pending the EU-wide
review of what is an appropriate prudential regime as
a whole for firms in the investment sector in 2015? If
not, please explain why not and propose alternative
approaches and the rationale for those approaches.
Q26: Do you agree to our proposal to retain current CRD
rules in force on Pillar 2, Pillar 3 and systems and control
requirements in SYSC (including the Remuneration Code)
for BIPRU firms keeping the ‘status quo’ pending the EUwide
review of what is an appropriate prudential regime
as a whole for firms in the investment sector in 2015?
If not, please explain why not and propose alternative
approaches and the rationale for those approaches.
Q27: Do you agree to our proposal to grant CRR-based
permissions with effect from 1 January 2014 to those
firms currently holding an eligible waiver related to
a GENPRU / BIPRU rule – listed in tables 12 and 13 –
provided the conditions in paragraph 7.6 are met? If
not please explain why not and propose alternative
approaches and the rationale for those approaches.
Q28: Do you have any comments on our cost benefit analysis?
Q29: Do you agree with our proposed approach to the
national discretions? If not, please indicate the areas of
national discretion where you disagree with the FCA
proposal stating your reasons and alternative proposal.
Q30: Do you believe that there are any articles in the Directive
or in the Regulation –not covered in Annex 3 – which
would require the FCA to exercise its discretion as a CA?
If so, what articles would you suggest and why?
94 July 2013
Financial Conduct Authority