Following the Government decision that FSA should regulate sale and rent back activities as soon as possible, FSA is consulting on an interim regulatory regime that would apply from the time the new laws take effect (probably July 2009) until the middle of 2010, when a full regime would take effect.  

FSA has based its plans on the Treasury consultation and plans a regime where firms must apply for interim permission. Once they have it, they will be subject to:  

  • the threshold conditions, including the fit and proper test;  
  • the Principles;  
  • some of SYSC (chapters 4, 5 and 9);  
  • several parts of MCOB (from chapters 2, 3, 5 and 12);  
  • fees rules;  
  • specific reporting requirements; and  
  • FOS rules.  

FSA wants comments by 1 May.