During December 2023, the FSCA issued an update relating to the roll-out and implementation of the Omni-CBR Roadmap in FSCA Communication 33 of 2023.
The intended roll-out was previously communicated in a Roadmap by the FSCA in June 2022. The roll-out would be in four phases over four years, from June 2022 – June 2026 as per the table below. Click here to read our previous article.
During 2022, stakeholder engagements were held with the FSCA hosting various webinars and targeted workshops with each of the sectors impacted by the Omni-CBR to provide additional clarity, resolve outstanding questions, and seek initial feedback on the draft Omni-CBR template.
Despite the consultation period on the draft Omni-CBR template having formally closed on 10 August 2022, several requests for extensions and late submissions from industry on the draft Omni-CBR have resulted in the FSCA experiencing significant delays in the overall processing and consolidation of industry feedback.
Extensive consideration of a wide range of comments has since taken place with the FSCA having consolidated and analysed all the feedback to identify and prioritise common emerging themes and concerns from the industry, some of which relate to the structure, format, and functionality of the draft template; data collection challenges; and confidentiality of reported information.
For the FSP sector, in particular, the following issues were raised:
- Questions about whether the reporting pertains to Key Individuals (KIs) acting as representatives or management KIs.
- Suggestions for providing data in respect of financial products rather than financial services, as quantifying the number of services provided for every financial product might be challenging.
- Questions on how the value of financial services for the book of business needs to be calculated for a CAT I FSP.
Overall, the stakeholder feedback has highlighted several important factors and concerns that require further consideration and broader consultation. The key themes are addressed in detail in the FSCA Communication.
In light of the voluminous and critical feedback received from the industry, the FSCA announced that the draft Omni-CBR template is currently undergoing a number of changes, including a significant streamlining of data points.
What is expected during 2024?
The FSCA aims to publish a revised and streamlined version of the draft Omni-CBR template in 2024 together with an industry survey, and to further engage with stakeholders.
This will result in the initial implementation timelines being extended. The FSCA is currently reviewing the timelines and a further update will be communicated in due course.
The FSCA confirmed that during the first half of 2024, work will continue on Phase 1 and Phase 2 activities in the Roadmap (i.e. consultation on terminology and data requirements, and assessment of systems and operational impact).
The following timeframes are targeted:
- Continuing with follow-up industry engagements to clarify outstanding issues raised in respect of the current version of the draft Omni-CBR template until 1 April 2024.
- Publishing a revised, streamlined version of the draft Omni-CBR template by 1 July 2024.
- Publishing an industry survey on the potential operational and systems impact of implementing the revised Omni-CBR requirements by 1 July 2024.
The planned industry pilot will be launched in the second half of 2024 based on the outcomes of the survey referred to above. Further updates on the progress relating to the Roadmap will be provided by 1 July 2024.
A more granular breakdown of the extended timelines for Phase 3 and Phase 4 of the Roadmap will be communicated during 2024.
The above timelines are also subject to possible revision during 2024 considering further refinement and harmonisation efforts that may be required following from the pending enactment of the Conduct of Financial Institutions Bill (CoFI Bill).
During 2023, our Masthead members and customers have benefitted from Omni-CBR discussions, during which Compliance Officers explained the contents of the Omni-CBR and have assisted FSPs in assessing requirements against their own capabilities to identify areas that may require attention.