Feedback on the Consultation Paper on 2022 Fees (2021-11-12)

Summary

This is the Guernsey Financial Services Commission's feedback statement on its 2022 Fees Consultation, summarising the 24 responses received and confirming the fee changes that will actually be implemented for 2022. It covers four main strands: an overall fee increase, a restructuring of investment sector fees, fee changes flowing from the Revision of Laws project, and a new cap on pension scheme member fees.

• Overall fee increase: The Commission will implement an overall fee increase of 7.6% (reduced from the originally proposed 10.1%), effective 1 January 2022, with revised fee amounts set out in Appendix 1.
• Investment sector restructuring: Fee bandings for the investment sector will be restructured as outlined in the consultation paper, increasing costs for the largest firms relative to smaller ones, effective 1 January 2022.
• Revision of Laws fee changes: Fee amendments arising from updated sector laws (which came into force 1 November 2021) will take effect 1 January 2022, including a new Change of Controller fee and clarification that primary/secondary licence category changes do not increase fees.
• Pension scheme fee cap: A cap on per-member pension scheme fees will be introduced at 7,500 members, effective 1 January 2022, designed to be broadly cost-neutral for the sector.
• Ancillary vehicles: No fee will be imposed for 2022 relating to notification of activity in respect of Ancillary Vehicles, pending outcome of a separate consultation.

The document is informational feedback on a closed consultation rather than new legislation, but it confirms the fee levels and structural changes that licensees, funds, and registered businesses will be charged from 1 January 2022, as detailed in the accompanying fee schedules.

Key obligations

• Licensees, collective investment schemes, registered businesses and registered individuals must pay the revised fees set out in Appendix 1 from 1 January 2022.
• A fee is payable for each new Controller involved in a change of control, irrespective of the number of entities or laws under which the entity is licensed.
• Pension scheme fees per member are subject to the introduced cap of 7,500 members from 1 January 2022.

Applies to

licensees, collective investment schemes, registered businesses, registered individuals, applicants for licences or registration, investment sector firms (designated persons, brokers, fund managers, investment exchanges), fiduciary licensees, pension scheme providers, prescribed businesses, non-regulated financial services businesses

Deadlines

• 1 January 2022: New/revised fees (overall increase, investment sector restructuring, Revision of Laws fee changes, and pension scheme fee cap) come into force.
• 1 November 2021: Updated sector laws underlying the Revision of Laws fee changes came into force.