1. CP 12/31 Removing the simplified ILASBIPRU firm automatic scalar increase andother minor changes to BIPRU 12A CEI Compliance FSA Consultation Papers Summary

2. What Is It All About?This will be of interest to all BIPRU firms.BackgroundOn reassessment, in the contemporary economic climatethe costs of the FSA liquidity regime have been higherthan originally thought on introduction in 2009. TheBank of England has also recently made additionalcontingent liquidity available. The FSA now wants toconsider amending the BIPRU 12 regime to account forits assessment of the economic costs and the availabilityof this additional liquidity insurance by recalibrating allindividual firms liquid assets buffer requirements. 3. What Is It All About?No specific rule change is necessary to achieve thisposition for standard ILAS BIPRU firms because of theguidance status of their quantitative liquidityrequirements and the FSAs firm intention not toincrease, across the industry, the calibration of individualfirms liquidity guidance.Despite that intention, simplified ILAS BIPRU firms aresubject to a specific calculation in determining theirliquidity requirements, the calibration of which isspecified in the transitional rules in BIPRU TP29. Toachieve a similar outcome for those firms requires a ruleamendment. 4. What Is It All About?Specifically BIPRU TP29 applies to all simplified ILASBIPRU firms between 1/12/2009 and 31/12/2015. Thisestablishes a transitional period during which simplifiedILAS BIPRU firms are required to increase their liquidassets buffers. Simplified ILAS BIPRU firms are currentlyrequired to hold 50% of simplified buffer requirements.The increase to 70% simplified buffer requirement is dueon 1/7/2013 and to 100% on 1/1/2016.The FSA are therefore proposing to amend the simplifiedbuffer requirement and delete BIPRU TP29 to recognisethese different circumstances. This is also intended toensure that the calibration of the simplified bufferrequirements remain consistent with the liquidityrequirements of the standard ILAS firms. 5. What Is It All About?This move is also in line with the recommendation of theinterim Financial Policy Committee (FPC) , whichrecommended at its meeting of 6/2012 that the FSAconsiders whether adjustments to micro-prudentialliquidity guidance are appropriate, taking some accountof this additional liquidity insurance. 6. So What Does It Say?In CP12/31 the FSA propose amending BIPRU TP29 Liquidassets buffer scalar: simplified ILAS BIPRU firms toremove the automatic increase which is due to come intoeffect on 1/7/2013 and all subsequent scheduledincreases.The effect of this will be that simplified ILAS BIPRU firmswill need to continue to maintain a Liquid Assets Buffer(LAB) that is not less than 50% of the simplified bufferrequirement. Furthermore, to delete BIPRU TP29 fromthe Handbook and amend the simplified bufferrequirement in BIPRU 12.6.9R to require a LAB of atleast equal to 50% of the current calculation. 7. So What Does It Say?In the FSA Handbook BIPRU 12.7 sets out criteria forassets that can be included in the LAB.At present, high quality debt securities issued by agovernment or central bank and reserves in the form ofsight deposits with a central bank are subject to certainrestrictions in terms of the credit quality of thegovernment or central bank and the currencydenomination of the assets.CP12/31 proposes to add a new rule to BIPRU 12.7 sothat similar credit quality and currency requirementsapply to securities issued by a designated multilateraldevelopment bank. 8. So What Does It Say?A minor amendment is also proposed to correct a smallnumber of drafting errors in the FSA Handbook SUP 16Annex 25 Guidance notes for data items in SUP 16 Annex24R.Given the need to implement the proposed change to theliquid assets buffer scalar for simplified ILAS BIPRU firmsbefore the automatic increase takes effect on 1/7/2013,and the relatively minor nature of the other proposals,the consultation period for feedback on these proposalsis (only) one month.Next stepsComments are requested by 8 December 2012. 9. What Is This Presentation This is a regulatory summary service provided by CEI Compliance Limited, The UKs Fastest Growing Regulatory Consultancy We can only advise on the salient points in this summary and if you want further details then we would suggest you access the full document from the FSA Website at www.fsa.govuk 10. 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There areeconomies to using someone who can base their fees oneach situation and not on a pre-determined service scaleor need for reaching a practice quota. This means quitesimply better value to you. 15. And, additionallyThe benefits of dealing with the ComplianceDoctor and CEI Compliance is;A firm with experienced and qualified formeradvisers;A firm that can apply changes and needs in acommon sense way that is practical andeffective;A firm that is considered and respected asindependent and reliable by the FSA;A firm that provides you with unfettered accessto the principle immediately and on demand; 16. Questions? More Information?CEI Compliance LimitedCall 0800 689 9 689 Emailinfo@ceicompliance.co.uk