Wind-Down Plans

Wind-down planning

Wind-down planning has proven to be a key focus for the financial services sector, especially for payments and e-money institutions who are being asked to send their plans to the FCA.

At present, investment firms are allowed by the FCA to determine themselves whether they should have a wind-down plan but it will become a requirement under the Investment Firms Prudential Regime in 2022.

What is a wind-down plan?

A wind-down plan is a firm’s plan to close down its regulated business and relinquish its regulatory status and it maps when that decision has to be taken and identifies all the steps necessary from communicating to staff and customers to terminating contracts with suppliers.

While it seems counter-intuitive to give thought to closing a business when every other activity during a working day is spent on making the business more successful, the intention is to ensure that if the worst comes to the worst, the business can be wound down without undue difficulties for customers and economic harm.

As a living document it should be refreshed periodically and after any material change in business/operating model. Our clients find the process of developing the plan sharpens focus on the fundamentals of the business, the interdependencies and in evaluating risk.

 

What does wind-down planning involve?

The development of the wind-down plan requires input from stakeholders from across the business to understand the people, services and contracts that must be continued to operate on a scaling-back basis. We will collaborate with you to build the wind-down plan together using our tried and tested template to achieve a bespoke plan with efficiency. We will lead a number of workshops and in between the workshops, we will draft the plan.

 

How we can help?

We are in an excellent position to share our experience and knowledge in devising robust wind-down plans that are tailored to both the FCA’s expectations and bespoke to your entity.

We apply our understanding of your business model, operations and your current and forecast financial situation to develop a robust and bespoke wind-down plan which is specific to your current situation.

We also offer assistance in the preparation of a slide pack for presentation of the wind-down plan to your board and support in responding to FCA questions.

If you have any queries on wind-down plans, feel free to get in touch.

One of the biggest challenges in wind-down planning is to accurately estimate the costs that will be incurred while executing a solvent wind-down of business operations.  

This guide analyses the data of ten payment and e-money institutions who have undertaken the wind-down planning process and looks at the average cost of winding down a regulated business. 

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