Under the Investment Firms Prudential Regime, or IFPR for short, firms are categorised as either SNI - small and non-interconnected, or non-SNI.
SNI firms are those which fall below defined threshold based on assets under management, client orders handled, balance sheet assets and revenues, and which don’t hold client money or client assets and do not deal on their own account. They are subject to fewer rules and less scrutiny than non-SNI firms.
The majority of firms in the regime, around 70% or so, are categorised as SNI firms and will benefit from a number of carve-outs in different areas of the regime, which I’ll highlight now, but watch the video dedicated to each area for more details.
For capital requirements, SNI firms calculate the higher of their Fixed Overhead Requirement or the Permanent Minimum Capital Requirement, whereas non-SNI firms also calculate their total K-Factor Requirement, again subject to the ‘higher of’ test.
For regulatory reporting, SNI firms will be required to submit fewer returns on a quarterly basis as the two items pertaining to concentration risk will not apply.
For Remuneration Code, SNI firms will only be required to apply the Basic tier of remuneration rules, giving greater freedom to disapply some of the stricter provisions.
For public disclosure, SNI firms will only be required to disclosure some quantitative and qualitative information about remuneration, but nothing in respect of capital, liquidity, governance, risk or investment policy.
One area where no carve-out is available through, is in regards to the ICARA process. Unlike the EU regime, all investment firms are required to carry out an ICARA process.
Watch the videos dedicated to each of these sections for more specific information.