Quarterly Consultation

The FCA’s Quarterly Consultation CP15/28 proposes miscellaneous amendments to the Handbook ranging from the list of appropriate qualifications under TC to restricting the scope of section C of the RMAR to money held in respect of insurance mediation activity.

There are a couple of areas worth highlighting as they are likely to be relevant to the majority of firms.

Although there have been recent changes to DISP concerning the resolution of complaints – see Regulatory Roundup 65 and 66 – further amendments are proposed. The complaints recording and reporting rules (DISP 1.9 and DISP 1.10) are being remade, although this is only for ‘technical reasons’ (page 36) and the ‘new’ rules will be the same as the current rules.  However as was mentioned in Regulatory Roundup 66 (further) changes to DISP 1.10 were to commence on 30 June 2016.  It is proposed that these further changes will now come into force on 1 January 2016. Fortunately this is not as bad as it first appears as the original commencement date of 30 June 2016 would apply to reporting periods which started on 1 January 2016 (para 7.12).

One helpful (real) change regarding complaints is in DISP 1.5 which will remove the need to keep the complainant informed where complaints are resolved by close of the third business day. However the quid pro quo is that the summary resolution must be sent ‘promptly’ (Appendix 7).

SUP 16.10.4 requires a firm to check its standing data within 30 days of its accounting reference date and submit any corrected data to the FCA. What constitutes standing data is set out in SUP 16 Annex 16A. It is proposed to extend the standing data that firms are required to keep up to date to include the name of the firm’s principal user on GABRIEL and their email address (see Appendix 6 of CP15/28).