Appendix G Retail Mediation Activities Return (RMAR) top tips This section provides you with some top tips to help you fill in and submit your Retail Mediation Activities Return (RMAR). In addition to these top tips, the Handbook contains more formal guidance on what information we expect from firms: www.fshandbook.info/fs/docs/sup/sup_chapter16_annex18bg_20121214.pdf A set of frequently asked questions (FAQs) is also published on our website (www.fca.org.uk ) which we hope you find useful when completing your RMAR. How do I log in? Log in through the GABRIEL section of our website www.fca.org.uk You can use the Forgotten password? link, on the login page, to reset your password. Once logged into GABRIEL: The first screen is the reporting schedule, where all returns are listed both present and future. The far right column will indicate what status the return is in e.g. Overdue which will be in red or Ready which will be in green. To submit your return, you must have completed and validated every data item in your return. Each data item can be submitted separately, unless it needs to be cross validated with another data item. To confirm that you ve submitted your RMAR please select the View Submission History link on the left-hand side of the screen where all the previous RMARs you ve submitted will be listed. To print your returns, please click on the Print link at the top of the screen When completing your RMAR Don t forget each data item of the RMAR has a help page, which you can find via the Help link at the top of each data item. There are also help links alongside some of the questions, in the form of question marks. Here are definitions of some of the terms you may come across when completing your return: Appendix G RMAR top tips 1 April 2013 Version 1
RMA-A Balance Sheet Tangible assets - Assets that have physical substance. For example, stocks, buildings and equipment. Intangible assets - Assets that are not physical in nature. For example, copyrights and patents, intellectual property and goodwill. When calculating your firm s capital resources in RMA-D1/D2, intangible assets must be deducted as these are not readily realisable or cannot be realised instantaneously so are ineligible to be part of a firm s regulatory capital. Net current assets - Total current assets minus Total amounts falling due within one year. Net assets must be the same as the Total capital. RMA-B Profit & Loss Account What to report Profits and losses should be reported on a cumulative basis (i.e. year to date) throughout the firm s current financial year, i.e. firms submitting half yearly should report six months income on the half-year return and 12 months income on the end-ofyear return. Firms submitting quarterly should report three months income on the first quarter return and then 6, 9 and 12 months income on subsequent returns. Gross & Net figures For mortgage and general insurance business, firms must add their gross commissions to their fees and other income. For investment business, firms need to add their net commissions to their fees and other income. Fees/Adviser charges/consultancy charges Should reflect adviser and consultancy charges, as well as net income received from customers or other sources on a fixed fee rather than commission basis, but only for the relevant regulated activities. Other income (regulated activities) Any income that has derived from the relevant regulated activities, which has not been recorded under commissions or fees. For example, interest on client money or payments made by product providers other than fees or commissions. Other Revenue (income from non-regulated activities) Gross revenue arising from the firm s non-regulated activities, if any, should be entered here. RMA-C Client Money and Assets Notifiable issue firms must notify us of any notifiable event or breach relating to client money rules. Client money account types firms must indicate the applicable type of account that it holds. Risk transfer a written agreement between the intermediary firm and the insurer where the insurer may agree to let the firm hold money as agent on its behalf. Statutory trust account client money held by firm in a trust account, with the firm acting as the trustee. However, the firm is not permitted to make credit advances from the client money account. Non-statutory trust account client money held by firm in a trust account, with the firm acting as the trustee; the firm may extend credit to its clients or insurers. Regardless of which type of trust account is being operated, a firm should never make advances of credit to itself out of a client money trust account e.g. by withdrawing commission before the premium has been received or before funds have cleared. Appendix G RMAR top tips 2 April 2013 Version 1
RMA-D1 Regulatory Capital & Financial Resources Is the firm exempt from these capital requirements in relation to any of its retail mediation activities? Most firms are not entitled to an exemption from reporting their capital resource details. If you feel your firm is exempt from our capital resource requirements, please contact the Customer Contact Centre on 0845 606 9966 before completing section D1/D2 of the RMAR. Total capital resources We ask this question twice in Section D1. Both of these answers, in the middle and at the end of this section, must contain the same figure. Total capital resources This question, at the bottom of the section, needs to be the sum of all of the eligible capital listed above it. Total capital requirement Capital requirement + other FCA capital requirements + additional capital requirements for PII. Category of firm If your firm is a B3 Low Resource personal investment firm then please ensure that you indicate this within RMA-D1. This will mean you only need to complete the Own Funds Test 1 in RMA-D1. RMA-D2 Financial Resources Non MiFID Personal Investment Firms Own Funds is made up of eligible capital such as share capital, share premium account, audited/verified profits, short-term subordinated loans etc, less intangible assets, current year losses. Adjusted Net Current Assets is made up of net current assets as stated in the Balance Sheet less long-term assets or connected persons adjustments and any investment adjustments. RMA-E Professional Indemnity Insurance (PII Self-certification) Has your firm renewed its PII cover since the last reporting date? - You should answer Yes to this question if your firm has renewed its PII cover within the reporting period, if this is your firm s first RMA-E, or if your firm s policy details have changed within the reporting period. You should only answer No if you have not renewed your firms PII cover during this reporting period. Please Note: It is a requirement of your GABRIEL reporting schedule to capture your professional indemnity cover held. Some firms will have supplied this at the point of authorisation but please be aware you are still required to enter the details in GABRIEL in your first submission and subsequently when you renew again. PII basic information You should review your policy documents and provide the data elements requested accurately, ensuring your PII cover is fully compliant with the Handbook Rules. PII detailed information - policy excess You should review your policy documents to identify the standard policy excess and any increased excesses that apply to specific lines of business. If your policy has any increased excesses, insert the business type covered by the increased excess and then the excess figure. Annual income as stated on the most recent proposal form For personal investment firms this is the relevant income arising from all of the firm s activities for the last accounting year before the policy began or was renewed. For insurance intermediaries and Appendix G RMAR top tips 3 April 2013 Version 1
mortgage and home finance intermediaries, this is the annual income given in the firm s most recent annual financial statement from the relevant FCA-regulated business activities. Amount of additional capital required for increased excess(es) - If you have recorded increased excesses, you will need to calculate your firm s additional capital requirement against the highest excess amount. In calculating the amount of additional capital required, firms conducting investment business should consult the table in IPRU-INV 13.1.27. For mortgage and general insurance business, firms should consult the tables in MIPRU 3.2.14. The calculated figure should also be added to RMA- D1, when calculating the firm s capital requirement against the question Additional capital requirements for PII. RMA-F Threshold Conditions This section requires a firm to state if there have been any notifiable change to its Close Links or Controllers. RMA-G Training and Competence Total number of staff this should be the total number of staff/employee that worked for the firm as at the end of reporting period. Do NOT include staff that may have advised during the reporting period but were not employed as at the end of it. Lines 2 to 7 you should indicate in the applicable fields/columns the number of staff that gives advice, staff that supervise others to give advice, number of competent advisers etc. The total in the right hand column field should be the actual number of applicable employees rather a total of the three columns. RMA-H COBS Data This section requires a firm to provide data in relation to general conduct of its business and monitoring of Appointed Representatives (AR). For example, you should enter the number of AR(s) registered with your firm at the reporting period end, not the total number of AR(s) during the reporting period. RMA-I Supplementary Product Sales Data (i) non-investment insurance product information You are asked to provide aggregate data on advising and arranging activities (for non-investment insurance contracts with retail customers). This information enables us to ascertain the importance of each product type to the firm and to target thematic work in this area. (ii) non-investment insurance chains A chain is where a non-investment insurance firm passes their business to another intermediary rather than directly to the product provider. RMA-J Data Required for Calculation of Fees For mortgage and general insurance intermediaries You need to enter income figures in the FCA boxes only. For retail investment firms You only need to enter the amount of approved persons working at the firm within the Financial Ombudsman Service (FOS) box only. Appendix G RMAR top tips 4 April 2013 Version 1
Please note that RMA-J will be displayed in a return of its own (separate from the other RMA data items) and you will be required to complete this once a year depending on the firm s Accounting Reference Date (Financial Year End). RMA-K Adviser Charges Initial adviser charges adviser charges invoiced to retail clients during the reporting period for services that are not ongoing. Ongoing adviser charges adviser charges which are not initial charges invoiced to retail clients during the reporting period for an ongoing service. Number of lump-sum payments number of initial adviser charge payments invoiced as a lump sum during the reporting period. Please note that this section should be reported on a cumulative basis throughout the firm s financial year, except for the minimum and maximum adviser charges. RMA-L Consultancy charges Consultancy charges invoiced via product providers consultancy charges invoiced via retail investment product providers who facilitate, directly or through a third party, the payment of consultancy charges. Consultancy charges invoiced via platform service providers consultancy charges invoiced via platform service providers who facilitate, directly or through a third party, the payment of consultancy charges by means of a platform service. Please note that this section should be reported on a cumulative basis throughout the firm s financial year, except for the highest, lowest and typical consultancy charges. RMAR- help text Please visit the GABRIEL section of our website for detailed RMAR help text. Appendix G RMAR top tips 5 April 2013 Version 1