Foolproofing ICARAs for 2024
It has been two years since the Investment Firms Prudential Regime (IFPR)
came into force and many firms will have now completed the second iteration of their ICARA.
For most of our clients, the first iteration of the ICARA took longer than
expected as they grappled with understanding the requirements and
assessing the risks inherent to their business. Many firms pushed back some
of the development of their ICARA to the following year, having been
surprised by the amount of work involved.
Indeed, the FCA was not expecting firms to get it perfect the first time, but
there were higher expectations of version two. From what we have seen,
and noted below, there is still work to be done.
