As you will know, BIPRU 12.1 – 12.4 (and 12.8 where relevant) applies to all BIPRU firms, whilst the remaining BIPRU 12 chapters only apply to ILAS BIPRU firms (limited scope and limited activity BIPRU firms are not ILAS firms; full scope BIPRU investment firms that meet the exemption in BIPRU 12.1.4 are also excluded from the definition of an ILAS BIPRU firm).
There are some minor changes to BIPRU 12.3 (‘Liquidity risk management’) and BIPRU 12.4 (‘Stress testing and contingency funding’), although based upon the table in 4.71 they do not result in substantive changes. Changes are also proposed to BIPRU 12.6, although these will only be relevant to firms that adopt the simplified ILAS approach. Elsewhere the FSA044 (‘Analysis of assets and deposits by maturity band’) will be phased out.
The proposed changes to BIPRU (and to SUP 16 guidance notes on the completion of relevant FSA returns) can be found in Appendix 4 of the QCP.
