Following recent States of Guernsey announcements on exiting lockdown, the Guernsey Financial Services Commission has clarified its expectations in relation to deadlines for key financial returns going forward.
One-month delay
As per its March announcement, the Commission confirms that firms have an additional one month to submit the relevant returns due to be submitted at the end of May, June, July, August and September 2020. After 1 October, all new returns will revert to the normal submission schedule.
The information reporting dates for the quarterly returns remain unchanged – only the submission dates have been extended by one month. For example, Form 141 Designated Manager Quarterly Return for Quarter 2 2020 will still cover April to June 2020 but under the extension will not be due for submission until 31 August 2020.
The Commission notes that to date, approximately half of all returns have been received in line with original reporting deadlines and the extension has not been used.
The relevant returns will have their respective submission deadlines automatically extended by one month on licensees’ online portal timelines. For example, Form 126 Pension Scheme or Gratuity Scheme Quarterly Return for Quarter 1 2020, normally due for submission on 31 May 2020, will now be due on 30 June 2020.
There will be no financial penalty for using this temporary one-month extension, but after 1 October financial penalties for any late returns will revert to normal.
Audited financial statements
As per the 24 March announcement, the Commission is temporarily relaxing the requirement for these audited financial statements to be submitted until 1 October 2020. To date, however, the vast majority of submitted financial statements have been audited.
If licensees need to submit unaudited financial statements in the first instance in line with the one-month extension policy, the Commission will ask for the audited financial statements along with any related management letters to be submitted by 1 October 2020.
If unaudited financial statements are initially submitted, a notification should also be sent to the Commission using a Form 200.
The Commission will request the audited accounts by asking for a resubmission of the original form. The relevant form will be reinstated on an entities’ timeline in the online submissions portal.
Any firm that knows it will not be able to make the revised filing deadlines should email the Commission to explain what issues it is experiencing, how it is remediating these and when it expects to be able to file. Investment and fiduciary firms should email ifpd@gfsc.gg and insurance and banking firms should email conduct@gfsc.gg
Full list of affected returns
• 123 Fiduciary – Audited Financial Statements and Statistical Return
• 124 Fiduciary – Annual Return – Full Fiduciary
• 125 Fiduciary – Annual Return – Personal Fiduciary
• 126 Fiduciary Pension Scheme or Gratuity Scheme – Quarterly Return
• 127 Fiduciary – Pension Scheme or Gratuity Scheme – Annual Return
• 131 Insurance Intermediary Annual Return
• 132 Insurance Manager Annual Return
• 133 Insurer Annual Return
• 135 Non-Locally Incorporated Domestic Insurer Annual Return
• 136 Insurer Half Yearly Return
• 141 Investment Designated Manager Quarterly Return
• 142 Investment Audited Financial Statements and Compliance Returns (Licensee)
• 143 Investment Audited Financial Statements (Funds)
• 144 Investment Half-Yearly financial statements Class A Funds
• 145 Investment Quarterly Return