10th September 2008

Compliance Tip - September 2008 - The coming of GABRIEL

By the 1^st October all regulated firms will have migrated to the GABRIEL system (GAthering Better Regulatory Information ELectronically) for submitting their regular FSA reports (e.g. the RMAR or specific data item). The FSA will provide the “principal users” of the previous reporting system (Firms on-line or the Early Reporting System) with log-on details which they can use to access the new GABRIEL system. Once these details have been received the user can log onto the system and begin to familiarise themselves with the new reporting processes.

GABRIEL Summary – GABRIEL looks and feels very similar to the Firms on-line system and therefore existing users of Firms on-line should be familiar with the general structure and methods of navigation and submission, however there are a few differences which are summarised below:

Help Menu – The structure of the help menu has changed. There are now two help menus, one specific to the return and its validation rules and one section containing general help on using the GABRIEL system.

Submission Methods – A wider range of submission methods are available. In addition to the standard “on-line” submission, firms can choose to complete returns off-line using a PDF document which is subsequently uploaded to the GABRIEL system, or firms can create more complex “web upload” or “direct communication” systems. The standard on-line system is likely to be the most appropriate option for most firms, especially those without a dedicated IT support team.

User Profiles – Existing user profiles for other staff members and external support (e.g. from compliance consultants) may need to be re-established. For firms who have allocated Resources Compliance user rights to view their firm's on-line system, these may need to be re-established, we will contact affected firms in due course explaining how this can be done. Users can be established with the following user profiles:

• Principal User – One individual per firm with full access to all areas of the system
• Firm Administrator – Such users will have almost unrestricted access to the system, similar to the profile of the Principal User
• Normal Firm User – The permission profile can be managed to limit or enable access to particular elements of the system

Submission – The submission system will work in much the same way, however there may be an increased need to “cross validate” sections (e.g. making sure that the information in one data item is consistent with information in other data items) and firms will be able to submit their returns in parts (e.g. submitting particular sections of the return as and when they are completed), although all of the information required must still be submitted in accordance with the timescales.

Resubmission – If a need to re-submit is identified (for example, because the return included material inaccuracies), a request to resubmit will need to be made on the GABRIEL system and a reason for the resubmission must be given.

System Availability – Users should note that the system will have limited availability in the short term, at least until the end of October 2008, when the system will only be operating between 8am and 5pm, Monday to Thursday.

General Points – The GABRIEL system appears to provide a greater level of security and a better audit trail for firms. The navigation and submission systems are quite straightforward and more intuitive than the Firms on-line system however as with any new technology the system may experience some problems in the early weeks and months, and therefore we would suggest that firms ensure that they complete their returns well ahead of schedule where possible.