Recently the Financial Sector Conduct Authority (FSCA) published Communication 16 of 2022, about the Omni Conduct of Business Return (Omni-CBR). The roadmap for the roll-out and implementation of the Omni-CBR and the draft Omni-CBR template (an excel spreadsheet) was also published.
The Communication included information about various industry engagements planned by the FSCA to provide explanatory guidance and solicit initial feedback on the draft Omni-CBR template.
YouTube videos (recorded by the FSCA) are available as an introduction to the Omni-CBR. Links to the YouTube videos are contained in the Communication, which is available on the FSCA website.
Written commentary was invited on the draft Omni-CBR template.
The idea is that from a future date most financial institutions (see below) will be required by law to submit online quarterly information to the FSCA. Thus, the term “Omni” as it applies to many types of financial institutions. This provision of information will entail answering questions prescribed by the FSCA. The FSCA will then use the information financial institutions give to them (and other information) to supervise the financial institution in relation to whether it treats its customers fairly and how it conducts itself.
The Omni-CBR will be the main (not the only) supervisory tool for the FSCA to obtain information from financial institutions. It will be compulsory, statutory reporting. It will form the “cornerstone of the FSCA’s off-site supervisory toolkit”.
Consultation and implementation of the Omni-CBR will take several years. By June 2026, all the relevant financial institutions will be required to be accurately and fully reporting on a quarterly basis in compliance with the Omni-CBR.
There are implementation steps laid out in the roadmap, including testing and compliance on a best effort basis. The four phases of roll-out are summarised in the roadmap as follows:
The draft excel spreadsheet includes the information that the FSCA requires and can be obtained on the FSCA’s website. This spreadsheet is part of the consultation process and will still, therefore, undergo change. The spreadsheet consists of instructions, a declaration, definitions, a general section (which all the types of financial institutions will answer), customisable sections, and a number of tabs that include questions that are specific to the particular type of financial institution completing the spreadsheet.
The Omni-CBR includes current regulatory requirements as well as new requirements that are still in the pipeline. The FSCA states that the Omni-CBR takes into account key financial sector regulatory reforms currently underway, such as the FSCA’s sector-based regulatory harmonisation project, the Conduct of Financial Institutions Bill, and outstanding proposals from the Retail Distribution Review.
More information on the Omni-CBR categories of information can be found in the videos on the FSCA website.
The information that is required under the Omni-CBR will be refined during the consultation and test phases.
The Omni-CBR still has a long way to go. Once finalised, it will become a vital supervisory tool for the FSCA. Thus, it is in the interests of financial institutions and their customers to understand and engage in the Omni-CBR as it is developed and executed. Management information, systems, and reporting will become even more essential for financial institutions. This is particularly true for retirement funds, as this is mostly new reporting for them.
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