FSA consults on organisational systems and controls requirements necessitated by CRD and MiFID implementation
On 19 May 2006 the Financial Services Authority (FSA) published Consultation Paper CP 06/9: Organisational systems and controls - common platform for firms.
CP 06/9 sets out the FSA's proposals for the new systems and controls requirements it will need to insert into the Senior Management, Systems and Controls sourcebook (SYSC) in order to provide for implementation of the Capital Requirements Directive (CRD) from 1 January 2007 and the Markets in Financial Instruments Directive (MiFID) from 1 November 2007.
The requirements of the CRD and MiFID overlap to a great extent. "Common platform" firms is the term used by the FSA to describe those firms to which both the CRD and MiFID will apply. The common platform is intended to provide a clear set of unified rules, which will be located in new topic specific chapters in SYSC. This approach will involve some superequivalence and would appear to be supported by cost benefit analysis, however the FSA is ready to provide parallel CRD and MiFID requirements if the industry challenges its cost assumptions in certain areas.
Comments on CP 06/9 are requested by 19 August 2006.