Dear CEO, your reporting is not good enough

In February the FCA wrote to the CEOs of IFPRU and BIPRU investment firms instructing them to review their regulatory reporting practices. The regulator is concerned about the quality of prudential returns, and the risks associated with inaccurate and incomplete returns. Even minor errors can “materially distort data”.

The investment firm CEOs were given a heads up that the FCA will review a sample of returns as of 1 October 2018. If they have not improved in quality, the regulator will “consider next steps”.

In 2017 ICAEW published an assurance framework for banks’ regulatory ratios and reporting which may be helpful for investment firms seeking to undertake similar work. Our guidance can help structure the necessary review of regulatory reporting practices, which could be performed by a special project team, internal audit or an external assurance provider depending on the needs and position of the firm.

The guidance allows a piece of review work to be done on a modular basis and tailored to your business model and requirements, avoiding the need to set out on an end-to-end process review right away, but target necessary areas using a risk based approach. It is flexible and covers governance through to substantive testing of reporting as needed.

The Financial Services Faculty is always keen to know where our guidance is used and if it has been helpful, if you have comments, please do get in touch at