During this time of stress, the expectation remains that firms plan ahead and safeguard their financial resources. This means taking necessary steps to preserve capital in the light of potential demands on liquidity.
The FCA must be contacted before a firm is planning to draw down a buffer or if a firm is concerned it will not be able to meet its capital requirements/debts as they fall due.
In order to reduce harm to consumers and markets, firms should maintain an up-to-date wind-down plan that takes into accounts the impact of COVID-19 on the business operations and the relevant steps to be taken for an orderly wind down, if necessary.
Repayment of capital or payment of dividends or variable remuneration can only be made after management has satisfied itself that such pay-outs are prudent given current market circumstances and consistent with their risk appetite.
You can find the FCA's official statement here.
You can find our last article about 'The FCA’s expectations on financial resilience' here.
If you need to discuss capital adequacy planning, intend to make distributions or update your ICAAP documentation and wind-down plans, please get in touch with your usual Buzzacott contact or send us a message through the form below.