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While the Regulatory exams are the main area of focus for most FSPs, there are still a substantial number of people who have an important deadline coming up next month.
This applies to all those FSPs who operate (legally) without a compliance officer.
Their reporting period is calculated from “authorisation date” or “the date of the last report” up to the end of December 2009. Compliance Reports may only be submitted AFTER the reporting date, but must be submitted ON or BEFORE the final submission date, which is 28 February 2010.
If this applies to you there are a couple of points you should consider.
Submission Logjam
Last year, those people whose reports were due on 15 August were given an extension to 15 September due to access problems, mostly relating to the site being inundated with people trying to submit their reports.
The fact that more than half the licensed entities at the FSB are sole proprietors who are not legally obliged to appoint a compliance officer means that the situation will be considerably worse as we get closer to the deadline date. The FSB clearly states on its website that no extensions will be given.
The guidelines on registration for the electronic submission of the report states:
- Due to high volumes of reports being submitted at the end of each submission period, you are encouraged to attempt to submit the reports before the end of the submission period. Past experience has indicated that the electronic submission system becomes overloaded over the last three days before the submission period ends, and reports do not always import successfully.
- If you registered last year, you will still be on the system, provided that your e-mail address did not change. If not, we recommend that you make time to register now for this year’s submission. Please click here to download the instructions as provided on the FSB website.
- Some other important considerations appearing in the guidelines include the following: “If you need to submit compliance reports for different years, it MAY NOT be submitted on the same day. Please submit it on separate days to avoid that the report being rejected.
- Confirmation will be send as soon as the report is imported on the FSB’s systems this can take up to 24 hours. Please keep proof of submission. We all know the importance of this advice!
- You may capture the report over a period of time and save all changes as you capture it if there is outstanding information that you need to gather before final submission.
- Only one compliance report should be submitted for each entity for a particular year. In the case where an entity is authorised for more than one category, only one reports needs to be submitted. The entity will need to submit the report that applies to the highest category that appears on the license, e.g. an FSP that is licensed for Category I and II needs only to submit the Category II report.
Manual Returns
Those FSPs who prefer to submit the report in hard copy format is advised to do so three weeks in advance to ensure that they get feedback on errors or omissions before the final date. As in the past, an incomplete submission will be treated as a non-submission, according to the regulator.
Compliance Report Workshop
Several compliance service providers will run workshops. Moonstone has extended its number of venues from 5 to 16 this year, thanks to the wonder of technology called satellite broadcasting. Please check here to see if there is a “theatre near you”.
Part of the presentation will be a live registration of an FSP registering, which we trust will remove the fear that many have of doing so.
Registration closes next week, so please register now if you intend attending. This will assist us greatly in finalising arrangements. |
