January 11, 2023

Dear CEO Letter - Wholesale Brokers

AFEP would encourage members to read the Dear CEO letter to wholesale brokers. Whilst not applicable to APIs and EMIs, it gives a good insight into the FCA's approach to Financial Risk and implications on wind down plans, remuneration and governance & controls.

The FCA have already suggested SMCR will be applied to Payment Services in the future, so firms are advised to understand the rules and regulations early and prepare accordingly.