Just when you got used to completing data item FSA009, it changed. Just as you are probably getting used to completing and submitting FSA003 via the Early Reporting System (ERS), wholesale changes to the reporting requirements, submission frequencies, deadlines and methods are upon us.
The last time we reported on integrated regulatory reporting (IRR), we informed you that the start dates had been deferred from 1 January 2008 to 30 June 2008 for BIPRU firms and 31 August 2008 for non-BIPRU firms. However, as with many projects involving IT systems, the roll-out has not gone quite as the FSA originally planned.
On 1 July 2008, ten new data items were made available for BIPRU firms, including FSA001 (Balance sheet), FSA002 (Income statement/profit and loss account), FSA008 (Large exposures) and FSA019 (Pillar 2 questionnaire). The remaining BIPRU data items have been deferred and are due to launch with the data items for non-BIPRU firms on 31 August 2008.
However, the Mandatory Electronic Reporting (MER) system that firms will use to submit these items will not be launched at the same time. Due to the start date of the MER system, GABRIEL (GAthering Better Regulatory Information ELectronically), being deferred to 26 August 2008, the FSA has introduced a staggered submission timetable for the new data items and GABRIELLA (GAthering Better Regulatory Information ELectronically Late Alternative), another interim system for some firms. Firms will need to submit data items in various ways.
BIPRU €730k And Multilateral Trading Facility Firms
- Submit FSA003, FSA004 and FSA028 via the existing ERS
from 1 July to 25 August 2008.
- Submit the new data items available from 1 July 2008 via
GABRIELLA in accordance with the IRR submission
deadlines.
- Re-submit these new data items via GABRIEL following its
launch on 26 August 2008.
BIPRU €125k And €50k Firms
- Submit FSA003, FSA004 and FSA028 via the existing ERS
from 1 July to 25 August 2008.
- From 1 July 2008, collate the information required for
the new data items and submit these via GABRIEL following its
launch on 26 August 2008.
Non-BIPRU firms are not affected by this as the 'go live' date for their new data items is 31 August 2008, i.e. after the revised GABRIEL launch date.
GABRIEL will hopefully be worth the wait as it will have a number of useful functions, such as viewing reporting schedules for the next 12 months, providing computer-based training and the ability to make practice submissions via a trial facility.
In addition to IRR, BIPRU firms will also need to consider the reporting requirements of Pillar 3. These are detailed in chapter 11 of the BIPRU handbook and can broadly be split into two categories.
- Qualitative disclosures regarding the risks the business
faces and how these are mitigated.
- Quantitative disclosures of regulatory capital
structures, financial resources requirements and how these
are met.
These disclosures will need to be made available to the public, via the annual financial statements, the firm's website or upon request. If they are not disclosed in the financial statements, the statements must state where the disclosures can be found.
Pillar 3 disclosures will have to be made annually. However, initially, the qualitative disclosures must be made available as soon as practicable during 2008, while the quantitative disclosures are not required until 2009. These should also be made as soon as is practicable, but this later date means the financial data they will be based on can be audited.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.