In this consultation paper, we feed back on the outcome of the consultation we conducted in October 2018 (CP18/32) on the variable fee we will charge professional body supervisors (PBSs) in 2018/19 to recover the costs of establishing and running the Office for Professional Body Anti-Money Laundering Supervision (OPBAS). We are also consulting on removing the minimum fee threshold from our fees model.
The key topics for feedback are:
- Many respondents to CP18/32 presented strong arguments for and against our minimum fee structure. Following an internal review of our consultations since 2017, we concluded that:
- We remain satisfied that 6,000 individuals is a reasonable point at which to set the minimum fee threshold. Under this structure, all PBSs pay a minimum fee of £5,000 plus a variable rate fee on the number of individuals they supervise above the threshold. For 2018/19, the variable rate fee would be £41.65 per individual.
- We do not have sufficient evidence to assess the impact that removing the threshold would have on PBSs and the individuals they supervise. We have therefore decided to consult on the removal of the threshold and ask PBSs to provide evidence of the effect this would have.
- We confirm our proposal to align the timetable for reporting the number of individuals PBSs supervise with the annual reports they submit to the Treasury – they should report by 31 October preceding the relevant fee-year the latest figure available for the year ending the previous 5 April.
- We agree that PBSs should not carry out a new data reporting exercise for 2019/20 and so we will re-use the data they reported to us in 2018 to calculate their 2019/20 fees.
Proposal for consultation
Our proposal for consultation is that we should remove the minimum fee threshold and instead charge a fee of £20.59 on all the individuals supervised, subject to paying no less than £5,000.
Who this applies to
This CP applies to the PBSs listed in Schedule 1 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and any other professional bodies considering applying to be listed.
It will also be of interest to designated professional bodies.
What you need to do
Please send us your comments by 26 April 2019.
You can also:
- email your responses to [email protected]
- write to us at: David Cheesman, Financial Conduct Authority, 12 Endeavour Square, London, E20 1JN
The consultation closes on 26 April 2019. We will confirm at the end of July whether we are retaining or removing the threshold and finalise the appropriate fee-rate, issuing invoices from August onwards. At the same time, we will consult on the 2019/20 fee rate, with a view to feeding back at the end of the year and issuing invoices in the New Year.
15/03/2019: Document update Added full list of respondents to CP18/32