Following the creation of the FCA and PRA and the renaming of the public Register, we expect firms to review their documents and other disclosures as a priority, to ensure they are up-to-date and accurate, so as not to confuse or mislead consumers.
Where we have been legally able to, we have given firms a transitional period for doing this, for example for the relevant requirements in the FCA Handbook General Provisions and related disclosures in KeyFacts documents. However, where obligations derive from European law, we are not able to do this. This includes obligations in the Payment Services Regulations 2009 and in the FCA’s Handbook - including, for example, certain provisions in COBS 5, COBS 6, COBS 9 and COBS 13.
The FCA recognises that in the exceptional circumstances arising out of the creation of the FCA and PRA, it may not have been possible to make all the required disclosure updates immediately upon the change, but (where transitional provisions are not available) firms must be able to demonstrate that they have plans to make these updates at the earliest practicable opportunity.