With phased implementation previously planned from 31 December 2013 the regulator announced a further deferral, this time, to 2015.

In the new post RDR world firms have to commit significant additional resource. This can be to provide a more rounded service, tackle additional investment oversight or to solve more basic problems, such as the collection of regulatory data, notably for the statutory Retail Mediation Activities Return [RMAR].

The future of legacy income, the transparency of adviser charging and the level of reporting detail expected are all issues that will deserve significant attention.

Tim Hines, business and strategy consultant at Optimus Consulting, said, "The FCA's announced further deferral is most welcome as many firms were not prepared for the first phase in December of this year, confusion and uncertainty still prevail.
"Understandably, there is a danger that firms have prioritised other more pressing issues and that capital adequacy has been 'parked'; as a result, we believe that many firms will be exposed by the challenges they will face.
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"The new capital adequacy rules were not as simple as they might at first seem. To say that the new rules were just an increase in the minimum 'cash' requirement from £10k to £20k is naive and indeed dangerous. Whereas the increase looks relatively modest the reality is that the sum required is potentially much greater.

"The EBR is far more testing than most firms realise and we anticipate there being a need for significant changes in working practices and financial structures."

The key requirements and timetable:
The revised start date for the introduction of the capital resource requirement for personal investment firms (PIFs) is now 31 December 2015

The original implementation period was due to commence from 31.12.2012 to 31.12.2015 and can be summarised as follows:
Deadline EBR/Capital adequacy trade off Subordinated loan
31/12/2013 1 month (4 weeks) EBR or £15k No limit (except for Exempt CAD)
31/12/2014 2 months (8 weeks) EBR or £15k 400% limit
31/12/2015 3 months (13 weeks) EBR or £20k 200% limit