Regulatory Roundup 34 contained details of the FSA proposals for ‘recovery and resolution plans’ (RRP) (CP11/16).
All firms subject to CASS 6 and/or CASS 7 (client assets/client money) are required to draw up a CASS resolution pack. The Rules relating to this come into force in October and further details can be found in Regulatory Roundup 39.
The major part of CP11/16 was relevant to UK deposit takers and BIPRU 730K firms with gross assets exceeding £15bn. Such firms will be required to maintain ‘recovery plans’ (identifying options to recover financial strength and viability should a firm come under severe stress) and ‘resolutions packs’ (containing detailed information about the business and operational structure). In the light of various developments the FSA has decided to delay publication of the final rules and has therefore issued a Feedback Statement (FS12/1) and FAQs. The final rules “will be published no later than autumn 2012”.
The FSA intends to consult at a later date on applying RRP rules to the UK branches of non-EEA firms without UK subsidiaries.
