Frequency, media, location and frequency of publication of Regulatory Disclosure

Pillar 3

 

The method of disclosure chosen for your pillar 3 should be carefully considered. The spirit of pillar 3 is that the disclosure should be publicly available and so making your disclosures available at the firm’s registered office or upon request would not meet regulators expectations.

 

You must publish your pillar 3 disclosures on an annual basis as a minimum; making disclosures as soon as practicable. It is for you to determine whether more frequent publication is necessary in the light of the characteristics of your firm’s business and the extent to which risk exposures or other factors are prone to rapid change.

 

You should determine the appropriate medium, location and means of verification to ensure that your pillar 3 disclosures are effective. To the degree feasible, all disclosures should be provided in one medium or location. If disclosures are not included in the financial statements, you need to include a note in the financial statements as to where they can be found. Equivalent disclosures made by your firm under accounting, listing or other requirements may be deemed to constitute compliance with pillar 3 requirements.

 

Disclosure in your financial statements is considered effective if they are filed on a public register, but such statements should be filed as soon as the information becomes available for disclosure. The other issue with filing financial via a public register is that once they are filed the disclosures are not normally updated until the following year.

 

Website disclosure is seen as the most practical as it means that it can be updated at any point during the year. However, firms may find that pillar 3 disclosures are not compatible with the purpose of their website, so P3 offers an alternative basis for making your disclosure.

 

Stewardship Code

 

 

This should be kept up to date in accordance with the firm's current policy and requirements of the code. This is not a pillar 3 requirement but in the UK firms are expected to disclose their policy on their website or if they do not have a website, in another accessible form.

 

Remuneration Code

 

Firms are required under pillar 3 to make certain disclosures in respect of their remuneration policy.

 

Where you use a web-site to make public your pillar 3 disclosures, there is an expectation that you will also include your remuneration disclosure there.