As a result of intensive – and prolonged – negotiations between the European Council of Ministers, European Parliament and European Commission the 1 January 2013 implementation date of CRD IV came and went.
An EU press release advises us that CRD IV is now back on (albeit delayed) track following adoption by the European Parliament, although this is not the end of the story as it is still subject to a detailed review of legal drafting, translation into other official EU languages and formal approval by the Council. The FCA Statement on CRD IV confirms that if the legislation is published in the Official Journal before 1 July 2013 then implementation of CRD IV will be from 1 January 2014. If it is published from 1 July 2013 then implementation will be from 1 July 2014 – the FCA is planning on the basis of January 2014 implementation.
CRD IV will introduce the concept of a single rulebook to ensure a harmonised approach across the EU; a consequence of this is that most of BIPRU and GENPRU will be replaced. Under harmonised reporting, firms will be required to comply with ‘Common Reporting’ (COREP) – which covers capital requirements and own funds – and ‘Financial Reporting’ (FINREP) – which covers reporting for supervisory purposes. As such we will see the eventual disappearance of FCA Data items such as FSA003 (Capital Adequacy) under COREP and e.g. FSA001 (Balance sheet) under FINREP (although note as far as FINREP reporting is concerned that the FCA website does say “may be replaced for some firms if/when UK adopts FINREP”).
Firms will find the ‘COREP & FINREP’ link useful as it will provide access to the FCA’s current comments and views on harmonised reporting, the expected changes to FSA Data reporting and a further link to the COREP reporting templates on the EBA website within CP50.
On the basis of the original implementation date, the FCA was planning to begin collecting data under COREP for the period beginning 1 July 2013. The last official statement from the FSA was that data collection would now begin from 1 January 2014. Note that the reporting of own funds will be based upon calendar quarters and will not relate to a firm’s year end.
There will be a couple of consultations issued by the FCA later this year on CRD IV. For now, firms should give consideration to any system changes that may be needed as a result of the need to report on a calendar quarterly basis (see above) and review the data requirements within the reporting templates.
Although for convenience we refer to “CRD IV”, it is actually a combination of a Directive (on the access to the activity of credit institutions and investment firms) and a Regulation (on prudential requirements for credit institutions and investment firms).
The FCA has a dedicated mailbox to deal with any aspect of CRD IV harmonised reporting: COREP.Queries@fca.org.uk.
