The FCA has launched a new webpage which sets out when and how firms should prepare a wind-down plan. A typical wind-down plan should include:
- Scenarios – a firm should identify all the scenarios that could lead to it no longer being viable. The FCA expects firms to have adequate governance and control processes and MI monitoring in place to support timely wind-down decision making;
- Plan – a firm’s plan should steer it to wind down its business in an orderly manner once the firm has decided to stop the business (whether a voluntary decision or otherwise);
- Resources assessment – this should include both the financial and non-financial resources needed to support an orderly wind-down;
- Processes – firms should implement processes to identify and mitigate material risks or obstacles to winding down in an orderly manner. These might include, for example, issues that could lead to significant consumer harm or create significant adverse impacts on financial markets or other third parties.