As an auditor it gives me great pleasure in confirming that finally, (a day before some of the deadlines!) given the impact of Coronavirus (COVID-19), the FCA has released filing deadlines extensions.
This is of great relief to some companies who have found it difficult to meet the deadlines given the restrictions on travel and IT services. With an understandably greater focus on clients and business pressures, the returns and accounts may have also been a lesser concern for some in these uncertain times.
The extensions have also meant that for CBW, as the auditor of such companies, we can take a moment and make sensible judgements on the going concern basis. It also means that auditors generally can now resist the temptation to include blanket paragraphs in audit reports regarding going concern to ‘cover off’ any potential issues which COVID-19 may or may not have prevalent at the time of signing the audit report.
The submission deadlines have been extended for the regulatory returns listed below. The extension applies for submissions that are due up to and including 30 June 2020.
For example, if you have a return due on 22 May 2020 but a 2-month extension has been granted, the submission will need to be completed by Wednesday 22 July 2020. If the extended deadline date happens to fall on a weekend, the submission should be made by the next working business day. Those not included below do not have an extension and firms must submit their data in the usual timeframe.
With the FCA Supervisory department asking questions on cash flows and business plans of some regulated companies anyway, they will already be aware of the financial performance of those companies without the filing of regulatory returns. But it will ease the burden on some firms who may have some cash flow problems which could result in short term capital adequacy issues.
For small or medium-size businesses (paying less than £10,000 in fees and levies in 2020/2021) the administrative fee for late returns has been waived until 30 June 2020 (this also applies to any returns not listed below).
Companies are still expected to submit your return as soon as possible and should you miss a deadline (in the period up to 30 June), the FCA will send a reminder letter to you.
Over the coming weeks the FCA will continue to monitor the situation and will keep these changes under review.
SUP 16 handbook returns:
1-month extension applies for the following returns:
• COR001A (Own funds)
• COR001B (COREP Leverage Ratio)
• COR002 (COREP LE)
• COR003 (COREP NSFR)
• COR005 (Asset Encumbrance)
• FRP001 (FINREP)
• FSA004 (Breakdown of Credit Risk Data)
• FSA005 (Market Risk)
• FSA007 (Operational Risk)
• FSA008 (Large Exposures)
• FSA014 (Forecast Data from Firms)
• FSA017 (Interest rate gap report)
• FSA018 (UK integrated group – Large Exposures (UK integrated group)
• FSA019 (Pillar 2 Information)
• FSA055 (Systems and Controls Questionnaire)
• REP005 (High Earners Report)
• RMA-D2 (Financial Resources)
2-month extension applies for the following return:
• FIN-A (annual report and accounts)
You are not required to submit the following return for 2020:
• Employers’ Liability Register compliance return
Other Handbook returns:
2-month extension applies for the following returns:
• Annual financial reports (as required under Disclosure Guidance and Transparency Rules)
• Credit union complaints return (CREDS 9 Annex 1R)
• Complaints return (DISP Annex 1R)
• Claims management companies complaints return (DISP 1 Annex 1AB)