Monday 10 June 2013

Modifications to Initial Disclosure document

Given that you have  six months from 1st April 2013 to modify out any references to the FSA or Financial Services Authority, don't forget that the former regulator is mentioned extensively in the Initial Disclosure Document (IDD and CIDD).

At first glance this may seem a relatively easy conversion but there are a few things to watch out for.

Firstly, the FCA CIDD / IDD template does not appear to have been updated from the old FSA one. At least it hadn't when  I looked a week ago.

Then there is the matter of the Register. The FCA uses the term Financial Services Register to designate the old FSA register so it is not just a simple change of 'Services' to 'Conduct' as it were. The web page for access is here: http://www.fca.org.uk/firms/systems-reporting/register

Finally, there is the matter of the address of the FS Register. The template gives it as www.fsa.gov.uk/register  but if you attempt to access this then you will may, at the present time, fail to find the page. The actual address is : http://www.fsa.gov.uk/register/home.do

NB . Since identifying this  last point and publishing this blog post there appears to have been a change on the FCS site. The link www.fsa.gov.uk/register/ redirects to   http://www.fsa.gov.uk/register/home.do  and so now all is in order on this particular point.

Any of my clients wishing to sort this particular point out, please email me  a copy of your IDD or CIDD and I will update it  for you.

Don't forget that the issue of the CIDD is one of those matters for your MMR Implementation Plan and if you are one of my clients, I will be  contacting you very shortly about this.

No comments:

Post a Comment