When introducing the Investment Firm Prudential Regime (IFPR) in January 2022, we renamed and moved the definition of ‘Significant IFPRU firm’ used as one of the criteria for identifying Enhanced Firms under the Senior Managers & Certification Regime[1] (SM&CR). This was to retain the definition in our rules following deletion of the IFPRU sourcebook. A number of stakeholders have since highlighted that this new definition of ‘Significant SYSC firm’ could result in more firms being brought into Enhanced scope than under the previous definition as it had been understood and applied.
We plan to consult shortly to make changes necessary to clarify that only firms that would have been both Significant IFPRU firms and IFPRU investment firms under the pre-IFPR arrangements fall within the new definition of ’Significant SYSC firm’ for the purposes of the Enhanced Scope SM&CR regime. In the meantime, we wish to make clear that firms that have unintentionally come under the Enhanced Scope SM&CR Regime under the new version of Significant SYSC, need take no action.