Early reporting FAQs for 2008

For reporting period end dates from 1 January 2007 to 31 December 2007 the Key Data sheet (FSA009) should be submitted at the same frequency and due dates as your current returns. Non-EEA Subgroup (FSA028) is submitted half-yearly, and is due 30 business days after your period end. Please refer to Chapter 16.7 of the Supervision manual for further details.
For reporting dates from 1 January 2008 onwards firms will submit (where applicable) the FSA003 (Capital Adequacy), FSA004 (Credit Risk) FSA011 (Building Society Liquidity) and the FSA028 (Non EEA Sub Group) in line with their Accounting Reference Date (ARD) and submission timescales which are detailed in SUP 16.12.
The following table provides a useful overview of data to be submitted using ERS:

Yes. The content of the FSA028 (Non EEA sub-group) is changing and is due to take effect for reporting period end dates 30 June 2008 onwards.  The main changes affect the filter questions at the beginning of the data item, which allows a firm to indicate whether it is the lead firm in a non-EEA sub-group, for the purposes of reporting on capital and large exposures.

From 1 July 2008, you will be required to submit the revised FSA028 (Non EEA sub-group) using GABRIELLA until GABRIEL goes live on 26 August 2008. 

For reporting period end dates prior to 30 June 2008, you should continue to download the data item from the Early Reporting System (ERS) and continue to submit via the ERS.

We will be writing to certain firms who have been submitting the FSA028 (Non EEA sug-group) with further details. 

If you are uncertain on how the reporting changes affect your firm, please speak to your normal supervisory contact at the FSA or get in touch with the FSA Customer Contact Centre on 0845 606 9966 or at fcc@fsa.gov.uk .

Frequently asked questions regarding GABRIELLA

Yes. Until the strategic solution is introduced in the second half of 2008, CRD firms are required to submit their existing returns, in addition to their new CRD returns.

UK Banks

We do not have the flexibility to allow UK Banks who have difficulty in completing Section D of the BSD3 return to submit the return with the data omitted. We appreciate that the figures reported in Section D may need to be manipulated by firms to meet all the validation rules, and will result in incorrect figures for the firms' capital position. We will not be placing any reliance on this section of the BSD3. The firm's correct capital position will be monitored from the FSA009 (key data sheet) and FSA003 (Capital Adequacy). Firms may also find it simpler to allocate all the assets (other than those deducted form capital) to a single risk weighting band.

Unfortunately formal changes to the validation rules of the BSD3 would incur cost for firms and ourselves, and we want to keep these to a minimum.

Building Societies

We think that Table F on the QFS1 will present the greatest difficulties for firms to complete. However, we will not be relying on the capital adequacy calculations from the QFS1 (in other words Tables D and F) but will instead use the information on the FSA009 (key data sheet) and the FSA003 (Capital Adequacy).

As with the returns submitted by other types of firm, we will not be amending existing reports or submission mechanisms, including the validations that are applied to the data received. However, we do have the flexibility with the QFS1 to accept incomplete forms so, if a building society is having difficulty in completing Tables D and / or F in Form QFS1 it may submit the return with the data omitted in these sections.

Securities and futures firms, investment management firms and UCITS investment firms

For the existing reports by these firms (that will become BIPRU investment firms), firms should continue to complete them on the current basis, although that will mean that the capital adequacy data reported on it will be incorrect. We will instead rely on the FSA009 and FSA003 for the capital adequacy information, although the remaining balance sheet, profit and loss and most of the large exposures data should largely be unaffected. As with the returns submitted by other types of firm, we will not be amending existing reports or submission mechanisms, including the validations that are applied to the data received.

However we do have the flexibility to accept incomplete forms so if you are:

• An investment management firm (IMF) subject to CRD, you may submit your return only need to complete QFS1, QFS2, QFS5 and QFS6.
• A securities and futures firm (SFF) subject to CRD, you only need to complete the Profit and Loss, Balance Sheet and CFTC part 30(if applicable).

Personal Investment Firms

Those personal investment firms that become BIPRU investment firms will need to continue to submit the Retail Mediation Activities Return (RMAR) on the existing basis. However the numbers in regulatory capital sections, excluding D5 Large Exposures, will not be relied on by us, but we will instead use the FSA009 (key data sheet) and FSA003 (Capital Adequacy); the remainder of the RMAR will still be relevant and should be unaffected (other than large exposures) by the CRD changes.

We now have the flexibility to 'switch off' the regulatory capital sections D1, D3 and D4 within the RMAR.

Please contact your central compliance team for more information or contact the Firm Contact Centre by email fcc@fsa.gov.uk or by calling 0845 606 9966.

No. Firm's must continue to report existing data during the first half of 2008 (i.e. between 1 January and 29 June 2008). However, the frequency of some reports will change as we start the process of aligning firms to the new reporting frequencies from 30 June.

Investment Firms:

• BIPRU 730K (and some 125k) Securities & futures firms existing monthly returns become quarterly (125k quarterly returns will remain as quarterly reporters)
• BIPRU 50K firms existing quarterly returns become half yearly.

UK banks

• Quarterly reporting continues as before, though we have removed, from 1 January 2008, the need for any interim consolidations that would otherwise be required under SUP16.12.
• With regard to liquidity reporting, the last date for existing mismatch reporting will be 31 March 2008, to ensure that the existing report is not submitted immediately prior to the new quarterly data item FSA010 (Mismatch liquidity – banks) being introduced at 30 June.
• And SLR1 reporting ceases after 31 May 2008. [We will not collect the data on that form for reporting dates between 1 June and 29 June 2008].

Building Societies

• Quarterly reporting (on the QFS1) continues as before.
• The GAP report changes from monthly to quarterly.
  
  

At present firms are required to submit their CRD returns using the Early Reporting system (ERS).

All Data Items FSA003 (Capital Adequacy), FSA004 (Credit Risk), FSA009 (Key Data), FSA011 (Building Society Liquidity) and FSA028 (Non EEA Sub Group) are available to download from the ERS now.

Blank versions of the new returns are available on the FSA website. To ensure that you are submitting the correct version, you should only submit returns downloaded from ERS.

If you have not received your log-on details for ERS please contact our Firm Contact Centre by emailing fcc@fsa.gov.uk or by calling 0845 606 9966. Otherwise, please go to Doing business with the FSA and register your firm using the log-on details we have given you.

Invitation codes for the ERS will expire 60 days after issue. We recommend that you register on the ERS as soon as you receive your invitation code. The system will ask you change this to a password of your choice. The invitation code should be entered into the password field on the log on screen.

No. You only need to use your invitation code when you are logging onto the ERS for the first time or when your password has been reset.

Firms Contact Centre by emailing fcc@fsa.gov.uk or by calling 0845 606 9966.

Note: Principal Users are no longer able to reset other users passwords

No. You must continue to submit existing returns using your usual channels. You must only submit the Key Data Sheet (FSA009) and Non-EEA sub-group (FSA028 if applicable) FSA003 (Capital Adequacy), FSA004 (Credit Risk) FSA011 and (Building Society Liquidity) via ERS until GABRIEL is introduced. GABRIEL is the stategic solution for manadatory electronic reporting (MER).

If you have submitted your data item and you realise that you have made a mistake on your return and you want to change it you can just submit a new return with the correct information.

The system has been upgraded to allow you to indicate what previous submission you are replacing.

No. The ERS is an interim solution to enable you to submit the new returns, so we have not developed it to allow you to populate the returns automatically. The system was designed to input the data manually. However you can copy and paste figures from other spreadsheets or applications, although you will only be able to paste mulitple figures simultaneously if they are in adjacent cells in the Early Reporting spreadsheet.

Please note: If you copy and paste a figure into the spreadsheet you will bi-pass the in-built data type and range validation performed by the spreadsheet (e.g. you could paste a negative figure into a cell that should not allow a negative number). If this happens, when you upload your spreadsheet, the Early Reporting system will carry out data type and range validation again and may reject your spreadsheet even though the spreadsheet indicates that it is valid. If this happens you will be told which cells are in error and you will need to correct them before submitting them again.

No. To complete the new returns on the new reporting system you can download the returns, complete the form offline and then upload via ERS.

No, you cannot use Firms Online to submit new returns. You must only submit the new returns Key Data Sheet (FSA009) and Non-EEA sub-group (FSA028 if applicable) FSA003 (Capital Adequacy), FSA004 (Credit Risk) FSA011 and (Building Society Liquidity) via ERS.

You must submit all other existing returns using current submission methods.

If your firm has consolidated reporting requirements under BIPRU, a Group Reference Number (GRN) will be issued to the known highest level reporter within your group/consolidation and they should let you know what it is.

The GRN starts with "H" and has a 4 digit number i.e. H0204. Firms should use the GRN instead of their FRN when submitting their group data.

Please contact your central compliance team for more information or contact the Firm Contact Centre by email fcc@fsa.gov.uk or by calling 0845 606 9966.

No. You only have to submit data for authorised firms.

Yes. All the authorised firms in the group will also have their own reporting requirments and all BIPRU firms in the group have to submit their own FSA009, FSA003 and, if required, FSA004 if they are subject to the new reporting rules.

You can find details on Transitional Reporting arrangements for 2007 in Policy Statement PS06/10 Integrated Regulatory Reporting (IRR) Credit Institutions and certain investment firms Section 8, page 48. Details of transitional reporting arrangements during 2008 are set out in Handbook Notice 67, paragraphs 2.20 to 2.33 and further details are on our website.

More guidance on the new returns.

The Early Reporting System uses workbooks which have been developed using Microsoft Excel. These workbooks are compatible with Excel 2000, Excel 2002, Excel 2003 and Excel 2007 so you can use any of those versions of Excel to open the workbooks and enter your data. However, we are unable to accept workbooks that have been saved in Excel 2007 format, so if you are using Excel 2007, please choose the option to "Save a copy of the document" and then select "Excel 97-2003 Workbook" before uploading and submitting your file to us. Excel 2007 format files have a .xlsx extension, whereas earlier versions have a .xls extension.

All amounts must be entered in thousands (000s). However underlying data may be held on firms' systems at a greater level of granularity. When completing a data item in thousands, this may lead to calculated fields (e.g. sub-totals) not validating due to rounding errors. If any adjustments are needed to meet the validations, as a result of these rounding differences, these have to be made prior to the submission. Only validated data items can be submitted, and there are no tolerances for rounding differences.

Please contact your central compliance team for more information or contact the Firm Contact Centre by email fcc@fsa.gov.uk or by calling 0845 606 9966.

Yes. If you use formulae that might result in fractions, you must ensure that formula rounds the result to the correct number of decimal places. Most figures in Early Reporting are whole number, but solvency ratios in FSA003 are in two decimal places. If you don't round the results, then the spreadsheets will be rejected when submitted. If this happens you will be told which cells are in error and you will need to correct them before you submit again.

When you have uploaded a data item to the Early Reporting system a message will be displayed confirming that your submission has been successful and giving you a submission reference number e.g 12345-FSA003. You should copy this number back into your copy of the data item you submitted (into the filed called 'Unique ID no'. This will help you identify the submission if there are any queries between the firm and the FSA.

You can copy the number by highlighting it on the web page and clicking "copy" or Ctrl-C then paste the number into the fileld on the Data Item using "paste special" and select the "Text" option (because you will have copied the number as a html object). You will not be able to paste it directly into the field using the simple"paste" function or Ctrl-V.