FSA Clarification - Pillar 3: managing your disclosure publicly

As many firms finalise their 2009 accounts in the next few weeks, they are ensuring that their Pillar 3 disclosure meets the FSA rules.

In a recent survey of 100 firms by IMS, it was discovered that almost 20% of firms do not disclose their Pillar3 publicly. Instead, they prepare their disclosure document and offer to provide it to interested parties “on request”.

The FSA has now clarified whether the “on request” approach meets a firm’s Pillar 3 obligations.  In its updated Pillar 3 FAQ and in January’s study “ICAAP submissions – observations for Limited Licence Investment Firms,” the FSA stated that, “We believe that making disclosures available only ‘on request’ does not fulfil the spirit of making the information publicly available.”

They continued to say that “where a firm chooses to present its Pillar 3 disclosures in a separate document (from the accounts) and does not have its own website to host the disclosures, it should consider the availability of third party websites to host disclosures” and “must indicate in its financial statements where the disclosures can be found.” So it is clear that public disclosure is just that and the “on request” approach now needs to be abandoned.

If you would like to disclose your Pillar 3 publicly, www.Pillar3.eu is a convenient and effective way that firms can meet their obligations.  It is possible to list your disclosure on a public page or if you prefer on a private url which can then be disclosed in your accounts.

If you would like to discuss your Pillar 3 disclosure strategy please contact Stephen Burke or Jonathan Wilson, or if you would like to complete your disclosure using www.pillar3.eu, either log on or call Louise Yates.

18 March 2010

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