The changes are:
Firms that do not have permission to give a personal recommendation on a retail investment product (or provide related services such as arranging or executing a transaction) will not be required to report adviser or consultancy charging data in either Section K or L of the RMAR.
If an investment manager provides a personal recommendation on a retail investment product (or provides related services), they will be required to supply data on adviser and/or consultancy charges depending on their business activities.
Where a firm has a management charge which covers adviser charges and charges for services that do not relate to a personal recommendation on retail investment products, they will not be required to distinguish between these charges when completing Section K.
The timing and frequency of a firm’s current reporting requirements in completing their RMAR has not changed. Firms will not have to submit their first report for the new data requirements until their first full reporting date after 31 December.
We have also produced templates to show the general look of the new sections (K and L) and revised sections (B and G) of the RMAR on the policy PS11/13 webpage.
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