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Private Bank Briefing – March 2021

ESMA reminds firms on rules of reverse solicitation - In a statement published on 13 January 2021, ESMA reminded firms not established or situated in the EU of the MiFID II requirements on the provision of investment...more

FCA Publishes Review of Asset Managers’ Implementation of MiFID II Product Governance Rules

FCA found instances of non-compliance with the product governance rules which, in its view, increases the risk of investor harm. Background - On 26 February 2021, the FCA published a webpage setting out eight asset...more

PRA Publishes Findings on Its Evaluation of the SMCR

The PRA has released a largely positive report, along with nine follow-up actions and recommendations on the SMCR for PRA-regulated firms. Key Points: ..There is no need for major changes to the SMCR. ..There are...more

Brexit & Financial Services: Preparing for the End of the Transition Period [Video]

With the end of the Brexit transition period looming, many financial services firms are asking what they need to do between now and the end of the year to ensure regulatory compliance. In this episode of our Connected With...more

Private Bank Briefing: Issues Impacting the Private Bank Sector - December 2020

Ahead of the end of the Brexit transition period, on 31 December 2020, regulators in the UK and the EU have issued a number of updates: Share trading obligation - In relation to the potential conflict between the share...more

UK Chancellor Outlines Future for Financial Services Post-Brexit

Equivalence decisions for EEA states, green finance and fintech initiatives are at the forefront of the UK government’s priorities. On 9 November 2020, the UK Chancellor of the Exchequer, Rishi Sunak, delivered a statement...more

HM Treasury Consults on Post-EU Financial Services Regulatory Framework

The UK government signals a diversion from the onshored regime towards a more flexible financial services regulatory framework. HM Treasury has published a consultation paper marking the start of Phase II of its financial...more

UK Firms Granted Extra 15 Months for Brexit Onshoring Preparations

The FCA, Bank of England, and PRA have published updated rules for firms post-Brexit and intend to delay many (but not all) onshoring changes. Key Points: ..The FCA has published an updated version of the FCA Handbook,...more

Private Bank Briefing: Issues Impacting the Private Bank Sector - September 2020

On 22 July 2020, HM Treasury published a policy statement setting out the UK government’s rationale and proposed approach for extending the transitional period for third country benchmarks under the UK Benchmarks Regulation...more

Sustainable Finance and Climate Change Risk in Financial Services: For Insurers

In a July 2020 speech on climate action in the financial industry, Sarah Breeden, executive director for UK Deposit Takers Supervision, said the industry is “at the start of a critical decade for climate action where the...more

Private Bank Briefing: Issues Impacting the Private Bank Sector - July 2020

Brexit: Latest Updates - Private banks are currently going through a process of assessing the changes that need to be made to their systems and controls, in addition to client facing documentation, to facilitate the...more

FCA Consults on Post-Brexit Prudential Regime for Investment Firms

Important changes ahead for investment firms as the FCA’s Discussion Paper (DP20/2) indicates that the UK may depart from EU capital rules. Key Points: ..FCA consults on a UK capital regime that in some respects breaks...more

FCA Fails to Find Its Watersheds Moment in Adams v. Options SIPP UK LLP

The English High Court’s findings are likely to have wide implications, not just for SIPP operators but for all regulated firms. Key Points: ..Regulatory obligations are not intended to take precedence over contractual...more

FCA Calls on Firms to Develop a Purposeful Culture

The FCA’s latest paper on culture explores how firms can improve culture through a meaningful purpose. Key Points: ..The FCA explains how it expects firms to develop a more purposeful culture, and the benefits this can...more

AMF Proposals to Revive the Research Industry in France

The AMF has published a report containing a number of new proposals relating to production of research under MiFID II. Key Points: ..The report pointedly criticises the original MiFID requirements (most of which were...more

Third-Country Firms Operating Cross-Border Into the EU - Upcoming Reform

Firms outside of Europe should be aware of planned upcoming changes to how they access European markets. Key Points: ..The EU legislators have been reviewing various financial services regimes and developing reforms...more

Brexit: 10 Commonly Asked Questions

Q&As for UK Regulated Firms - Although the general election result has provided some certainty in relation to what happens next from a Brexit perspective, there are still many outstanding questions. In addition, a large...more

FCA Consults on SMCR for Benchmark Administrators

The FCA has published a Consultation Paper that sets out proposed rules for the SMCR for benchmark administrators. Key Points: ..The SMCR for benchmark administrators (that perform no other regulated activities) will...more

Research Unbundling - FCA Finds Rules Working Well

The FCA has published the findings from its review into firms’ implementation of the MiFID II research unbundling rules. Key Points: ..Overall, the FCA found that the rules have produced “positive changes” and have had...more

FCA Confirms SMCR Optimisations

The FCA has published final rules confirming amendments to the SMCR, and final rules for solo-regulated firms. Key Points: ..The FCA has confirmed that the Head of Legal does not require approval as a Senior Manager,...more

Private Bank Briefing: Issues Impacting the Private Bank Sector - June 2019

The FCA and the PRA published their Business Plans for 2019/20 in April 2019. FCA Priorities - As expected, with Brexit remaining a key focus, there are few new initiatives for this year. The FCA’s Business Plan sets...more

FCA Fires Warning Shot to Brokers in Wholesale Markets

Latest Dear CEO letter from the regulator includes strong criticism and warns that firms need to improve to meet regulatory expectations. Key Points: ..FCA supervisory work during the next two years will focus on four...more

Private Bank Briefing: Issues Impacting the Private Bank Sector

On 23 January 2019, the FCA published a Consultation Paper (CP19/4) concerning further amendments to the Senior Managers and Certification Regime (SMCR). For private banks which are already subject to the SMCR, the...more

MiFID II Costs and Charges - Room For Improvement

The FCA has issued feedback from its review of firms’ costs and charges disclosures under MiFID II. Key Points: ..The FCA found that, despite firms being aware of the rules and taking compliance seriously, firms are not...more

Brexit and Financial Services - FCA Issues Further Guidance For Firms

The FCA outlines how it intends to use its temporary transitional powers in a no-deal scenario. Key Points: ..The FCA has highlighted areas in which transitional relief will not be granted in a no-deal...more

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