Timely reminder on RMAR
The RMA return is often the only contact the FCA has with a firm so it is essential it is completed accurately as it provides them with an indication how your firm is governed, says ATEB Consulting’s Steve Bailey
The FCA recently published the appropriately titled ‘Retail Mediation Activities (RMA) A high-level summary of why we collect the data and how it feeds into our supervisory approach’ that can be accessed here.
The paper is aimed at intermediary firms that complete the RMA return, primarily investment, mortgage and non-investment insurance advisory firms.
The paper includes a reminder to firms that, if they are not using a permission they hold and have not done so within the previous 12 months, they should remove them. The FCA will be writing to those firms.
There should be nothing new to firms within this document but it is always useful to have a reminder to ensure standards have not slipped and that we don’t have any internal ‘Spanish Customs’.
While we can’t dissect every line from every form in this article hopefully some of the following reminders and ‘hints and tips’ will be useful when completing your firm’s returns. While the following list is not by any means exhaustive it should act as a reminder.
Hints and tips
Before you start your RMAR always have the most up to date versions of the following documents to hand:
Always remember the following when completing the RMAR.
• All figures should be reported on an accruals basis, the only exception to this is section K when you can elect to report on a cash basis;
• Unless it is a snap-shot, like the balance sheet, the figures are reported on a cumulative basis i.e. interim profit and loss is 6 month figures and the year end is 12 months.
RMA B – Profit and Loss Account
• Gross commission is total commission; net commission is the amount retained by the firm – note you do not take off payments made to ARs;
• Fees are net fees;
• For the total Regulated Business Revenue column mortgage and general insurance business firms should add gross commissions to fees whereas investment firms need to add net commissions to fees;
• Other income (regulated activities) could include – interest on client money or payments made by product providers other than fees or commissions.
RMA C – Client Money and Assets
• If, like most general insurance brokers, you hold client money, then care must be taken to complete this section carefully;
• It is important therefore to get professional advice (e.g. accountant of finance director) when completing this section;
• Please note the recent changes that require additional information that necessitates an analysis of the last 6 month’s client money balances.
RMA D1 – Regulatory Capital
• When recording the percentage of annual income record only that relevant to the business line i.e. for Home finance and non-investment insurance it is either 5% or 2.5% of the income derived from these lines and not the total firm income;
• Note if you were a ‘B3 low resource’ you will now simply be a ‘B3’ firm;
• Remember to remove you intangible assets;
• A reminder – capital adequacy is required every day and not just for RMAR ‘strike days’.
RMA E – PII Self-Certification
• If there is not a perfect match in any of the dropdown boxes you must provide a best match or ‘other’;
• For policy excesses all must be catered for in the answers. You should provide a ‘mop-up’ usually being ‘all other’ to ensure a summary of relevant excesses is evidenced;
• You must use the table IPRU-INV 13.1.27R to calculate additional capital resource requirements for additional PI excess and NOT simply add the additional excess onto your existing base figure;
• To calculate additional capital resource requirements for PI policy exclusions you must use table IPRU-INV 13.1.23R.
RMA F – Threshold Conditions
• This is one that sometimes gets overlooked, since it can be rarely used, but if there has been a change to close links or controllers this form must be completed.
RMA G – Training and Competence
• Only fill out the section relevant to the firm’s permissions;
• The full time equivalent is 2 decimal places;
• Number of staff that have passed approved examinations is for that time period being reported and not in total.
RMA I – Supplementary Product Sales Data
• Note the annualised premium (single and regular) is for new business and is cumulative i.e. first 6 months figures should be included in full year’s figures;
• Only tick ‘Yes’ in column ‘A’ if you have sold the product during the reporting period;
• All product areas need to be disclosed, for example, if critical illness is sold as an additional benefit to a life policy then both ‘life assurance’ and ‘critical illness’ boxes need to be ticked as ‘Yes’.
RMA J – Data required for calculation of fees
• As a sense check columns ‘B’ and ‘C’ should not be greater than column ‘A’ – if they are, check your figures.
RMA K – Adviser charges
• ‘Aggregate sum of the proportion of initial adviser charges, payable through regular instalments, due from retail clients within the reporting period’ – this reinforces the requirement for initial adviser charges taken over time to have a finite period so clients know exactly how much the advice will cost them. You must ensure the figures are reported every period for the life of the charge.
Finally, if you are in any doubt about your submission, it is worth checking out the FCA page of common misreporting errors here.
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