A couple of members have asked about this, thought it was easier to put online if anyone wants to comment, we're pleased suggestion 1 is in the mix. (amazing to see the growth in CICs in such a short time!)
Question 10: Do you have further suggestions or comments on how the Office for Civil Society can help frontline groups become more efficient and effective?
CICs are still regarded as 'new', so in many regards we're not really able to fully contribute to the wider dicussion that your having with all your stakeholders, so have limited this response to a few simple suggestions relating to CICs.
Help the Micro Boom create a Macro Effect
We would like to see a clear set of roles and responsibilities for infrastructure development of CICs to be set out. The legislation itself is working, but virtually nothing has been done to take forward the macro planning view of developing CIC. I have copied below a letter I wrote to your Office 18 months ago, which is still very relevant today. As an update we now have 974 members and there are over 4200 CICs.
I hope to be able to arrange some focussed meetings with your office to discuss particular suggestions, but in many ways we need to understand your wider strategy. Im available at short notice if there are any areas of interest.
You're currently reviewing Financial Services regulation, while your doing that you could consider CICs relativity.
Suggestion 1. a. Provide an exemption to CIC under the FSMA as you do for IPS, which would allow us to market for community-based investment, which could really make the difference in maintaining multi-stakeholder community activities.
I understand all Financial Services Regulation is being reviewed, so we would need to understand what will happen to adapt.
b.If you withdraw that exemption for IPS, we'd ask you make an exemption for companies looking for less than 100/250/500k, this would make it relevant for all SMEs.
c.If the legislation stays the same as current we'd request you support our plan to incorporate an IPS to become a central 'portal' for CICs that could be administered under the IPS exemption.
Suggestion 2 . We're developing the concept of CIC Bonds, which can provide a uniform set of protocols and procedures which will provide an easily understandable set of expectations to both investee companies and investors, and we would request you support/endorse/take over leadership on this issue. We hope to be accepted as a pilot with the Nesta pilots for the Big Society Bank , we believe the evidence and argument for developing a strategy now should be beyond argument.
We're building and learning as an Association so would need some support to be able to really accelerate the agenda, and welcome to the opportunity to contribute to the wider effort.
Beyond that, I hope you'll get behind all the good work that is being done on the ground and help us increase our footprint, a little packaging of CIC could go a long way.
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