Q: We treat our institutional investors as 'private customers' so it will be very difficult for us to identify these and exclude them from our PSD return. Can you please clarify whether it is acceptable for us to report transactions that include those to non-private customers?
A: While it would be preferable for 'non private' sales to be excluded from your PSD return, if it is not possible for you to do this, then you can include all transactions in the report.
Q: For ISAs, do we report the initial investment only, or all subsequent investments made in future years?
A: To clarify, PSD currently only relates to the customer’s initial investment so you do not need to report switches or further contributions (top-ups).
Q: Under the rules, are CIS operators required to provide PSD for nominee deals?
A: We are aware that, in most instances, the underlying customer data is held by the nominee firm and not by the CIS operator. So, although we intend revisiting this issue at a future date, the interim position we have agreed is as follows.
Nominee deals and deals via life companies will be excluded from the scope of PSD reporting.
However, if the CIS Operator arranges deals through an in-house ISA manager (that is part of the same group of companies) it should – where possible – include all individual personal holdings on the register in the PSD return.
We will re-consult on extending the scope of PSD reporting to external ISA managers, non-operator ISA managers, other platforms, fund supermarkets and aggregators at a later date.
We will be issuing a revision to the rules in a future Handbook Notice Update.
Q: How should a firm report a PEP/ISA wrapper – should they look through to the underlying investment?
A: At this point in time firms are not required to identify the underlying investment. PSD is a new supervisory tool and we have been keen to ensure that we do not ask firms to report data that we may not fully use. The requirements will be kept under review and may change as we (Small Firms Division) and other areas of the FCA/PRA identify other uses for PSD data.