ACCA welcomes the opportunity to respond to this consultation. We are grateful that the FCA has recognised many of ACCA’s views in paragraph 2.18 of the consultation paper.
We believe that the arguments retained in favour of the ‘minimum fee structure’ have been overplayed, and there is no reasonable and fair justification for capping the OPBAS fees for all those Professional Body Supervisors (PBSs) with fewer than 6,000 beneficial owners, officers and managers (BOOMs).
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