With effect from 1 April 2009 the UK Financial Services Authority (FSA) is extending the application of the “common platform” to firms not subject to the Markets in Financial Instruments Directive (MiFID) and Capital Requirements Directive (CRD). The changes will have the effect of extending the common platform to virtually all other firms regulated by the FSA (known as “non-MiFID/CRD firms”). It should be noted that for the time being the common platform will still not apply to insurers, managing agents and the Society of Lloyds.
The “common platform” refers to chapters 4-10 of the FSA’s Senior Management Arrangements, Systems and Controls sourcebook (SYSC). It covers:
- business structure and contingency planning;
- training, competence and expertise;
- compliance, internal audit and financial crime;
- risk control;
- record keeping; and
- conflicts of interest.
As a consequence of the changes, any non-MiFID/CRD firm proposing to enter into an outsourcing arrangement or to renegotiate any existing outsourcing arrangements after 1 April will need to take into account the outsourcing provisions in SYSC Chapter 8. Click here for a link to the FSA site which covers the upcoming changes in more detail.