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CRD IV: What and when to report

Does your organisation fall into scope of the latest Capital Requirements Directive (CRD IV) and Capital Requirements Regulation which came into effect on 1 January 2014?

Even though the Prudential handbook for Investment Firms (IFPRU) is already available online, there are still many key changes that the FCA has not managed to consolidate into it. Therefore, besides firms subject to IFPRU, organisations need to be very careful when referring to online guidelines because many of them will be out of date.

The specific application of rules to individual organisations is very complex and relies on a number of factors. This is just a brief guide on the FCA changes and the CRD IV core applications. If you are unsure how the regulations affect your organisation, you should look for specific professional advice. 

IFPRU organisations categorised as “IFPRU investment firms”, are automatically subject to the full CRD IV requirements and are no longer subject to BIPRU or GENPRU. These have been further sub-classified into the following groups: “full-scope IFPRU investment firms”, “IFPRU limited activity firms” and “IFPRU limited licence firms” that reflect the old BIPRU sub-categories, as well as Exempt IFPRU commodities firms.

All companies that were previously categorised as BIPRU limited firms will fall into the IFPRU limited licence firm category if they hold client money or provide safekeeping and administration services.  Although the IFPRU framework is based on the CRD III Pillar 2 regime (the old BIPRU and GENPRU versions), there is still a large set of new requirements that companies will be subject to, including: new financial reporting requirements, COREP and FINREP, and new rules on regulatory capital and pay regulation.

When all IFPRU organisations will be subject to COREP, not all of them will be subject to FINREP because this is only required on Consolidation Group basis, not on solo basis, where their capital is traded on a regulated market and are subject to International Accounting Standards.  

All IFPRU organisations will be required to submit their first COREP reports, electronically via GABRIEL, in XBRL format by 30 May 2014. After that, COREP submissions must be completed by defined dates that are about one month after the corresponding Reporting Date.


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