Preparing Your Firm’s Wind-down Plan
May
Why is Wind-down Planning Important?
The FCA’s wind-down planning guidance was published back in 2016. This has recently gained additional scrutiny and attention with the publication of the FCA page ‘Preparing your firm’s wind-down plan’ in March 2024. While the 60-page guidance itself does not impose any obligation on a firm to create a wind-down plan, the FCA do require some firms to submit a wind-down plan as part of their application for authorisation.
Those in the financial and consumer credit sectors should see an effective wind-down plan as a continuation of their operational resilience framework. Ensuring you have a plan if a wind-down is triggered is not only good business sense, but also boosts confidence in your business.
If your firm ceases its regulated activities and applies to cancel its permission, it is essential to do so with minimal adverse impact on clients, stakeholders and the wider markets. A wind-down plan is a live document that should be under continual review by the upper management and/or governing body.
Key Wind-down Planning Points
- Have a live wind-down plan that is regularly monitored and reviewed to ensure it is suitable and effective.
- Keep your business continuity plan (BCP) up-to-date with regular reviews.
- Set and test wind-down scenarios specific to your business type and model.
- Develop a wind-down risk management framework to identify and monitor the risks associated with your bespoke wind-down scenarios.
- Define risk metrics and early warning indicators and ensure good management information and reporting on these.
- Carry out operational and stakeholder impact assessments.
- Assign the roles and responsibilities where wind-down oversight is needed.
Other documents that go hand-in-hand with wind-down planning: –
- Regulatory Business Plan
- Business Continuity Plan
- CASS Resolution Pack
- Communications Strategy Plan
- Impact Assessment
- Operational Resilience Framework
- Important Business Services Assessment
- Treating Customers Fairly Policy
- Vulnerable Customers Policy
- Consumer Duty Framework
- Stakeholder Analysis & Mapping
- Important Business Services Assessment
Wind-down Planning Templates
If you are looking for professional, customisable templates to aid your wind-down planning obligations…look no further! Know Your Compliance Limited have provided more than 10,000 firms with regulatory templates and policies over the past 10 years. Specialising in FCA, AML and regulatory compliance, we are one of the market leaders in compliance templates.
Our recently launched Wind-down Policy & Plan Templates are the latest addition to our Operational Resilience suite of templates. If you have obligations under the FCA Handbook, these templates will save you time, money and stress! Our 36-page Wind-down Plan Template is accomapnied by a 19-page Wind-down policy and Excel based review log. All for just £45 (exc vat).
View Wind-down Templates! View All Operational Resilience Templates!