Amongst the rules for being an enhanced entity is where a company is a retail intermediary company with earnings of greater than ₤ 35m on a three year rolling average basis.
The detailed rules define this by reference to how companies adhered to RMA-B reports to the FCA, but the FCA has detected that some intermediary firms do not complete this return and alternatively complete a different regulatory return as a result of their particular regulatory permissions.
The FCA is proposing to amend its rules to guarantee that all retail intermediaries are caught by its rule. Non RMA-B companies with the relevant permissions will need to self-assess whether their revenue exceeds the ₤ 35m three-year rolling average criteria, both before commencement of the regime (by 1 September 2019) and annually thereafter.
If they meet the criteria, they must inform the FCA and will need to obey the enhanced company requirements by December 2019.
If they only meet the criteria in future years (i.e. after December 2019), they will have one year within which to carry out the enhanced business requirements.
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Lee Werrell Chartered FCSI FISM.
Head of Marketing.