Is your RegData reporting schedule correct?

If your RegData schedule is incorrect but you’re not sure how to tell the FCA what needs to be changed, we can help.

Recently, firms trying to correct FCA’s reporting system, RegData, have been met with requests from the FCA Supervision Hub for a detailed, technical explanation (quoting FCA Handbook rules) as to why the schedule may be incorrect.

Background

Changes to reporting schedules are usually necessary where a firm has changed its regulatory permissions and RegData has not been updated in turn. For example, where a firm has moved out of MIFIDPRU and IFPR and is no longer required to submit MIF returns.

If you aren’t familiar with the FCA Handbook, the term ‘prudential category’ may mean nothing to you. To summarise, given the vast array of firms the FCA regulate they are categorised into different ‘buckets’ based on the activities they carry out, any restrictions on what they can do (requirements or limitations on activities they can perform) and a host of other factors (for example, size of firm, and potential impact i.e., AUM, turnover, amount traded, number of appointed representatives are all relevant).

These 'buckets' or 'prudential categories' then drive the prudential rules that apply, for example how much capital/liquid cash is needed, whether PII is required etc.

There are well over 100 different categories and sub-categories and they in turn drive the 'financial' reporting via RegData.

For a 'data-based' regulator you would have thought making sure firms are submitting the right data would be a priority, particularly as most firms will only interact with the FCA via returns submitted through the RegData system. So, it was a surprise to hear that firms, when telling the FCA their returns are incorrect, are being asked to provide an expansive explanation quoting the FCA Handbook rules to demonstrate precisely why they are incorrect.

Whilst the onus is on firms to make sure they are submitting the right returns, given the complexity of the rules, you would expect a little support. Particularly as it is the FCA who are the ultimate arbiter of the RegData returns needed and firms are unable to make changes themselves. And sometimes, things simply do go wrong after a change. This is not news.

How can ComplyCraft help?

We are happy to help firms who are struggling to get this right. Please get in touch if you think something may be wrong with your reporting schedule or you are struggling to get RegData corrected. Even if you don’t believe there are any issues, we can review and provide assurance.

It’s likely simpler issues can be addressed quickly during an initial call. More complex changes can require a detailed, technical review of several Handbooks to determine which rules apply. Where this is the case, we can review and provide our findings to you.

A common issue we have helped resolve is where firms have moved out of MIFIDPRU and IFPR, so are no longer required to submit MIF returns. The relevant Handbook section below will demonstrate for many firms (i.e., depending on your firm's new 'prudential category') why MIF returns are no longer needed and which 'financial' returns will be required instead.

We hope you find this useful.