4

Initial steps

4.1

When a firm is considering undertaking an RFTS it should approach the regulators at an early stage. Early dialogue with the regulators will enable a realistic timetable to be established.

4.2

There will be close and frequent dialogue between the PRA, the firms, the nominated skilled person, the FCA and any home state regulator (where a transferee includes a firm authorised by an EEA state other than the UK) during which the scope and content of the scheme report will develop.

4.3

Before the nominated skilled person is approved by the PRA, they should avoid undertaking excessive preliminary work which may compromise or be perceived to compromise their independence.

4.4

The initial documentary information on the scheme should be provided to the PRA, shared with the FCA, and should include the broad outline of the RFTS including a provisional timetable. Firms should undertake and share their own assessment on the statutory question (detailed in section 5) in the course of their planning for the implementation of the ring-fencing regime. This analysis should be shared with the skilled person.