On 26 July, the Financial Conduct Authority (FCA) sent a Dear CEO letter to Portfolio Platforms, setting out reminders of their expectations in the following areas:

  • Operational resilience;
  • SUP 15 notification requirements;
  • Transfer times; and
  • Brexit

In respect of operational resilience, the FCA reminds firms that they expect firms to invest in their systems to ensure that they keep pace with the growth of their business and remain fit for purpose. The FCA points to Policy Statement PS21/3 which sets out final rules and guidance on building operational resilience with which firms should be familiar. The FCA reminds firms that the rules and guidance come into force on 31 March 2022.

On SUP 15 notification requirements, the FCA expects firms to notify them of any matter which could have a significant adverse impact on the firm’s reputation, or which could affect the firm’s ability to continue to provide adequate services to its customers. This includes material service degradation incidents e.g. operational disruptions. The FCA does not believe all material incidents at platforms that meet the SUP 15 requirements, are being reported to them presently.

As for transfer times – the FCA indicated it was pleased with the progress of this and that it would be carrying out a review of STAR MI in 2022. On Brexit, the FCA provides a brief reminder that firms are obliged to assess the impacts of the transition period ending, and apprise customers where relevant.

To view the Dear CEO letter, please click here.