CP15/42: response form

We are asking for comments on this by 4 January 2016 for Chapters 7 and 9, and 18 February 2016 for Chapters 2, 3, 4, 5, 6, 8 and 10 (see the Overview section for further details).

Please use the form below or alternatively, please send comments in writing to:


Chapter 2: Richard Johnson, Strategy and Competition Tel: 020 7066 4834
Chapter 3: Laura Royle, Policy Governance and Professionalism Tel: 020 7066 2382
Chapter 4: Sohrab Irannejad, Enforcement and Market Oversight Tel: 020 7066 7454
Chapter 5: Roy Bartholomew, Life and GI Policy Tel: 020 7066 1708
Chapter 6: Chris Bentley, Reporting Policy Tel: 020 7066 6126
Chapter 7: Steven McWhirter, Governance and Professionalism Tel: 0131 301 2164
Chapter 8: Rowan Hillery, Consumer Credit Policy Tel: 020 7066 7626
Chapter 9: Jonathan Rees, Primary Markets Policy Tel: 020 7066 2726
Chapter 10: Andrew Lowin, Prudential Policy team Tel: 020 7066 4506


If you are responding in writing to several chapters then please send your comments to Emily How in Communications, who will pass your responses on as appropriate.All responses should be sent to:

Financial Conduct Authority
25 The North Colonnade
Canary Wharf
E14 5HS

Telephone: 020 7066 2184

Email: [email protected]

We make all responses to formal consultation available for public inspection unless the respondent requests otherwise. We will not regard a standard confidentiality statement in an email message as a request for non-disclosure.

Despite this, we may be asked to disclose a confidential response under the Freedom of Information Act 2000. We may consult you if we receive such a request. Any decision we make not to disclose the response is reviewable by the Information Commissioner and the Information Rights Tribunal.

Note: You can take a printout of your response before clicking the 'Submit to FCA' button at the end of the form, but this will only print the visible text on screen, and you may have given longer answers. After submitting your response, the form will clear, but when we acknowledge receipt of your response by email, we can return to you a copy of your full submission as received. Check this box if you would like to have a copy of your submission returned:

Submission Details

as an individual
as a representative of an authorised firm
as a representative of a professional firm
other (please specify):

Chapter 2


Do you have any concerns about our consequential amendment proposals for the rules and guidance on controllers?


Chapter 3


Do you agree with the proposed changes to the forms and rules as outlined above?



Do you agree with the cost benefit analysis above?


Chapter 4


Do you have any comments on our proposed approach to amend EG7 in light of section 89NA FSMA?


Chapter 5


Do you agree with our consequential changes to the Handbook as set out in this chapter?



Do you agree that these proposed changes cover all the consequential changes necessary to ensure the organised functioning of the FCA Handbook? If not, please provide us with information on the further changes you deem necessary and why?


Chapter 6


Do you have any comments on our proposals to require compliance reports for banks to be provided to us via the GABRIEL system?



Do you have any comments on our proposal to amend the guidance notes relating to question C3.2 of MLAR?



Do you have any comments on REP-CRIM (the new Financial Crime Report)?



Do you have any comments on the guidance notes for REP-CRIM?



Do you have any comments on the proposed application of this reporting requirement to credit unions and friendly societies where they undertake activities in scope of the proposed rules?



Do you have any comments on the proposed revenue thresholds for relevant firms?



The data we gather in the proposed Financial Crime Return could be used to compile aggregated and anonymised statistics to provide industry-wide views on fraud risks or high-risk jurisdictions, for example. This could inform a firm’s own approach to the management of financial crime risks. Do you have any comments on this?



Do you have any questions or comments about our CBA?


Chapter 7


Do you know of any reason why these qualifications should not be added to and/or amended on our appropriate qualifications?


Chapter 8


Do you have any comments on the proposed amendments?


Chapter 9


Do you agree with our proposal to continue to apply the requirements for the approval, filing and publication process for prospectuses to listing particulars and supplementary listing particulars?


Chapter 10


Do you agree with these proposed changes to IFPRU?



Do you agree with the proposed changes to GENPRU, SYSC and the Glossary?