The latest IM deadline passed at the start of this month without fanfare, and larger firms were able to breathe their fourth sigh of relief. A year from now, the challenge will not be as “easy”.
In Phase 4, approximately 35 firms fell in-scope of the €750 bn threshold. Updated numbers for Phase 5 show that 314 entities are in-scope of the 50bn threshold, and an estimated 726 will be caught by the Phase 6, 8 bn threshold. Since BCBS/IOSCO’s recommendation to delay the final stage, national regulators have been slowly echoing this advice in their regulation. Australia is the latest regulator to confirm that they will also stagger their IM thresholds.
The new list of regulators that have formally acquired the requirements are now as follows:
As well as embracing the 2-step threshold, all national regulators above have also accepted BCBS/IOSCO’s wording that firms are ‘expected to act diligently’ in relation to IM documentation and custodial account setup, as soon as they become aware that their AANA calculation is approaching a threshold.Contact Us