FSA data items FAQs

Q: FSA001 requires us to report all currency figures in thousands. Does the same principle apply to data elements 65A, number of UK retail customers?

A: As data element 65A is not a currency figure, you are required to report this figure in units and not in thousands.

Q: What period should the first report on FSA002 at end June 2008 cover? We are a BIPRU investment firm with an Accounting Reference Date (ARD) of 30 September. Our existing prudential return submitted at end March 2008 contained the profit and loss data for the quarter to end March.

A: There is an important change in the data reported on FSA002, compared with the data previously provided. FSA002 must be compiled on a 'cumulative' or 'year to date' basis. All BIPRU 125K firms with a 30 September ARD will therefore report their income and expenses for the nine months to end June on their first FSA002 at end June. Similarly, other BIPRU firms with a 31 December ARD will submit the FSA002 covering the first 6 months of 2008.

Q: When changes were made to the Data Reference Guide earlier this year[KS3] , FSA006 was removed. Does this mean that this data item has been dropped or does it mean that the form still needs completing by firms, but they will not be able to submit it via the “Direct Communication” submission method?

A: FSA006 is still required but cannot be submitted through the Reg Data system. Currently, those firms that are required to report FSA006 do so electronically by means of an emailed file (Excel spreadsheet or comma-separated-variable file). The volume of data contained in FSA006 precludes it from online data entry and we have decided that we do not want to force firms to submit using direct XML submission through the Reg Data Gateway. Therefore, for the time being, firms should continue to submit the data in the format required by their CAD2 waiver (which is very similar to that required by FSA006).

Q: Our firm has not sought a CAD2 waiver. Do we need to inform our supervisor of our intention not to do so? If we do not notify them, will we be required to submit FSA006?

A: If your firm has not sought a CAD2 waiver, or has no intention of doing so, there is no need to do anything. FSA006 should not appear on your reporting schedule. Please also note that in any case FSA006 will not be available for data entry on Reg Data.

Q: Can you please clarify the intended reporting requirement for FSA007? Note 3 to SUP 16.12.6R states that the reporting date for this data item is 6 months after a firm’s most recent Accounting Reference Date (ARD) with firms then having to submit the return within 2 months. Under the tables for other Regulated Activity Groups, the note to add on 6 months to the accounting reference date does not exist.

A: The equivalent of note 3 to SUP 16.12.6R should also be carried through to SUP 16.12.12R, 16.12.16R, 16.12.23R and 16.12.26R (and this omission due to an oversight will be rectified in due course. As the data item goes live on 31 August 2008, it means that all firms with an ARD falling at end February 2008 and later will have to complete FSA007 (as long as the firm is not solely on the Basic Indicator Approach, when it does not need to report it).

Q: What is FSA015 and who should complete it?

A: This data item is to be completed by banks and building societies and provides the FCA and PRA with information on the credit quality of a firm's portfolio, enabling us to assess potential threats to the firm's viability. Data Element 1A-G to 11A-G - Balance of accounts - in arrears/default by band (1.5% to 2.5%, 2.5% to 5%, 5% to 7.5%, 7.5% to 10% and more than 10%).

Q: How do I report arrears which are less than 1.5% of the balance?

A: If the arrears are less than 1.5%, the firm does not have to report them at all.

Q: What is the submission period allowed for FSA015? PS 07/23 states that this data item is required to be submitted within 30 business days but SUP 16.12.7R shows the data item required within 20 business days.

A: The submission period as stated in the Policy Statement will apply, ie 30 business days. The Handbook will be updated in due course to reflect the fact the submission should be 30 business days.

Q: What is the position for reporting at UK consolidation group level? There seems to be a difference between PS 06/10 which states that this data item is required to be submitted at UK consolidation group level only in certain circumstances and SUP 16.12.5R.

A: A footnote will be added to the requirement for FSA017 in SUP 16.12.5R to clarify that this data item need only be completed at the UK consolidation group level for members of UK integrated groups or wider integrated groups. However, UK consolidation groups that do not have UK integrated groups or wider integrated groups will still have to complete this at both the solo/unconsolidated and UK consolidation group levels. This will be consistent with the intention set out in PS 06/10 (following paragraph 6.3).

Q: What discount rate should be used for row 43 of data item 17?

A: No standard discount rate is prescribed. It is up to the firm to select a risk adjusted yield curve that best represents their business book.

Q: Does a firm that is not intending to notify the FCA under BIPRU 10.11.1R (to apply BIPRU 10.7 or BIPRU 10.8) have to complete FSA018?

A: No. It only applies to those firms that have given notice where that notice is still in operation.

Q: Is reporting of all Wider Integrated Group (WIG) exposures required regardless of their size at the reporting date?

A: If the WIG's exposure to a diverse block is less than 10% of the group capital resources under BIPRU 10.8.13R at the reporting date, then it should not be reported on FSA018. However, if all exposures were less than 10%, a zero return would still be required.

Q: What period should the first report on FSA030 at end August 2008 cover? We are a Securities and Futures firm with an Accounting Reference Date (ARD) of 28 February. Our existing prudential return submitted at end June 2008 contained the profit and loss data for the quarter to end May.

A: There is an important change in the data reported on FSA030, compared with the data previously provided.

FSA030 must be compiled on a 'cumulative' or 'year to date' basis. All firms with a 28 February ARD will therefore report their income and expenses for the 6 months to end August on their first FSA030 at the end of September.

Q: Is the Funds under Management figure being reported here relevant for the calculation of our periodic fee? The guidance looks different to that in the FEES handbook.

A: The figure reported in this section will not be used for the calculation of your periodic fee. The definition of funds under management in FSA038 has been devised to reflect more accurately than the FEES definition the impact of the firm.

Firms will typically receive a completely separate communication asking for details of the relevant tariff basis according to their Activity Group.

As a reminder, for firms categorised as falling into activity group A7 – Fund Managers, the relevant tariff base is Funds under Management as defined in FEES 4 Annex 1 Part 2.

For firms falling into activity group A9 – Operators, Trustees and Depositaries of collective investment schemes and Operators of personal pension schemes or stakeholder pension schemes, the relevant tariff basis is Gross Income, also defined in FEES 4 Annex 1 Part 2.

Q: If we manage on a delegated basis a portion of a fund that is domiciled overseas, do we report the whole of the value of the fund of which we manage a portion?

A: No. We are primarily interested in the value of funds under management for which a UK regulated entity has responsibility. You should include a figure that represents only the portion of the fund for which you have been delegated responsibility.

Q: How do I enter my figure in thousands instead of units?

A: Monetary fields in this report should be submitted in thousands (000) and not single units (£). The RegData system will change the figure you enter from thousands into £ by adding 000 after you have submitted. If you enter in single units (£) you will be entering a much higher figure than you intended.

For example: 10000000 (£10,000,000) will be submitted as £10,000,000,000.

If you intended to enter £10,000,000 then you should enter in thousands as 10000.

Q: I have entered 0 in 1A and 0 in 5A and have received a warning message. What does this mean?

A: If you have entered 0 in 1A and 5A this means you have not used your permissions in this reporting period. The warning message is prompting you to consider if you are not intending to use them in the next reporting period you may wish to review or vary your permissions.

Find out more details about varying your permissions[1].

Q: Please clarify what is meant by "percentage of clients that are retail clients". Does it refer to:

• clients with funds under management?
• clients with whom the firm undertakes Designated Investment Business (DIB)?
• all clients (which could include ordinary banking clients)?

A: We intended that there be a degree of pragmatism around the figure that is entered here, especially as there are only four possible ranges. It is easy to see why including ordinary banking customers as 'retail clients' would distort the figures substantially. Therefore, as the data item is measuring both funds under management and DIB, the figure used as the numerator ought to cover retail clients for whom you undertake either activity.

Q: I am unable to submit FSA038 due to a validation error which requires data element 5A to be less than or equal to data element 1A.

A: The FCA and PRA's view is that for private equity firms 'total funds under management' (1A) should be calculated by reference to the total current value of investor commitments plus any undrawn committed capital (capital would include both capital and loans). Thus, it would not include any capital contributed by the firm, any capital which was drawn down to be used for management fees/costs or any amounts which were drawn-down and subsequently returned to investors.

'Drawn down capital' (5A) is a defined term and should represent the total current value of drawn-down capital, less those amounts used to pay fees/costs and those amounts returned to investors. On this basis, total funds under management should always be more than drawn-down capital".

Q: Does a BIPRU 50K firm which has a requirement in its Part IV permission preventing it from holding client money or assets have to submit FSA038 where it will have no data to report?

A: All firms will be required to complete FSA039, even although they may not be able to hold client assets. In these cases, a nil return will be required.

Q: Are we required to report FSA040? It seems from the rules that we would have to report it but we do not undertake that type of business.

A: We know there are a limited number of firms that are subject to the CFTC part 30 exemption order, and we will clarify the reporting rules to make it clear that it only applies to those specific firms. Reg Data will only require this from those firms that completed that section on the old securities and futures firms' returns.

Q: Is it possible for us to report to you the relevant data in the bands that we currently use (i.e. to 4 decimal places)? FSA045 states that reported PD bands should be 'mutually exclusive and numerically sequential'. It also requires these to be stated to 3 decimal places. We previously agreed with the FCA to use PD/EL ranges to 4 decimal places.

A: Following a review of this issue, we intend to remain with 3 decimal places on FSA045. We accept that this will result in a reduced level of precision.