Tuesday, 27 March 2012

Early IMAP submission postponement - knock on effects?

Having seen the comments of the FSA's man (p4) on those firms scheduled for early internal model application assessment (namely that "it is vitally important that submission slots are adhered to"), it seemed more than coincidental that the Lloyds of London application, due in at the end of April, has been pushed back 3 months.

Not sure of the drivers behind it (indeed it is worded like they are doing the FSA a favour!), but the recent release of this PwC document on "learning from the early movers" seems prescient, particularly around bridging gaps in preparedness! Alternatively, this article suggests that avoiding dual runs of ICA and internal model in 2013 has driven the delay.

Regardless, while the FSA have gone to some lengths in the IMAP industry presentation to ask for adherence to timescales, pleading personnel poverty, is there a danger that such a big player getting reassigned this early on will have knock on effects for other applicants?

Late post script - Lloyds FD put some words out in relation to the delayed application, justifying it after some FSA 'backtracking' on application completeness.

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