The European Capital Requirements Directive (‘CRD”) requires certain disclosures to be made by regulated firms which enable market participants to assess information on a firm’s risks, capital and risk management procedures. The FCA has implemented some of these requirements through the Prudential Sourcebook for Banks, Building Societies and Investment Firms (‘BIPRU’) and the Senior Management Systems and Controls Sourcebook (“SYSC”).
As BCM is a limited licence firm under BIPRU it is subject to the FCA’s rules on remuneration (“the Remuneration Code”). The Remuneration Code is set out in section 19A of SYSC. FCA regulated firms can apply the Remuneration Code in a way and to the extent that is appropriate to its size, internal organisation and the nature, the scope and the complexity of its activities. To this end, the FCA has created three proportionality tiers for categorising firms to which different standards apply when considering the application of the Remuneration Code.
BCM falls within proportionality tier three and so has more flexibility to dis-apply certain requirements compared to firms falling into the other tiers. Consequently, the BCM disclosure statement has been prepared by reference to the categories of information that the FCA considers should be disclosed by firms in proportionality tier three.