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The Edinburgh Reforms - Two Years On

When the Edinburgh Reforms were announced on 9 December 2022, they were billed as an ambitious set of reforms. Two years on, we assess which of the measures have been completed, which remain outstanding, and whether they have...more

Government Report Finds Financial Services Sector Could Work Better for Women

The Sexism in the City report highlights key issues affecting women in financial services and sets out a number of recommendations to address them. On 8 March 2024, the House of Commons Treasury Committee published its...more

FCA Publishes Final Rules on Sustainability Disclosures and Investment Labelling

The FCA’s long-awaited regime seeks to raise standards, increase consumer understanding, and reduce instances of greenwashing. On 28 November 2023, the FCA published its Policy Statement (PS23/16) containing final rules on...more

UK Regulators Set Out Policy Proposals on Misconduct; Diversity and Inclusion

The FCA and the PRA have published their long-awaited consultations which aim to formalise how firms approach diversity and inclusion. On 25 September 2023, the FCA and the PRA published separate but related consultation...more

UK Government Consults on Regulation of ESG Ratings Providers

The consultation considers what a potential regulatory regime would look like, and its proposed scope. On 30 March 2023, HM Treasury published a consultation on regulating ESG ratings providers, which ties in with and...more

FCA Seeks Improvements to ESG Benchmarks

The regulator is concerned that ESG-related disclosures are not meeting expectations. The FCA has published a Dear CEO letter sent to benchmark administrators on 20 March 2023, expressing concerns about the quality of...more

Consumer Duty Update: FCA Issues Dear CEO/Director Letters Setting Priorities for Sectors

The letters ask senior management to prioritise implementing the Duty. On 3 February 2023, the FCA published Dear CEO/Director letters underscoring the immediate (i.e., during the implementation period up until 31 July...more

Second FCA Consultation on New Prudential Regime for Investment Firms

Latest FCA consultation focuses on remuneration, risk management and governance, and liquidity requirements. Key Points: The consultation: ..Sets out the FCA’s proposals for the new remuneration rules for FCA...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

HM Treasury Announces Welcome Proposed Amendments to the UK Benchmarks Regulation

The proposals enhance the FCA’s powers to ensure an orderly wind-down of critical benchmarks and to deal with “tough legacy” contracts that cannot transition from LIBOR. On 23 June 2020, the FCA published a statement...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 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

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

FCA Consults on Further Amendments to the SMCR

The FCA seeks to clarify the position of the Head of Legal and the scope of the Client Dealing Function. Key Points: ..The FCA is proposing to exclude the Head of Legal from the scope of the Senior Managers...more

FCA Finalises Changes to its Financial Crime Guide

The FCA has finalised a new chapter on insider dealing and market manipulation. Key Points: ..Firms should take note of the new guidance, which applies immediately. ..Helpfully, the FCA has clarified that firms do...more

FCA to Clarify Scope of the Client Dealing Function

The FCA has announced that it plans to consult further on the scope of the Client Dealing Function under the SMCR. Key Points: ..The FCA acknowledges that the scope of the Client Dealing Function needs to be clarified,...more

FCA CP18/36 — The Second Brexit Onshoring Consultation

The FCA has published a second consultation on the Brexit onshoring project. Like the first, and many other Brexit onshoring documents, it is both long and very technical. However, a number of important policy points are...more

Regulators Publish Final Rules on SMCR Extension

The FCA and the PRA have published their Policy Statements, setting out final rules on the SMCR regimes for insurers and FCA solo-regulated firms. Key Points: ..The FCA has announced that the extended SMCR will apply to...more

Next Steps in the Asset Management Market Study

FCA publishes final rules and further consultation on outstanding remedies under its asset management market study. Key Points: ..The FCA has published a Policy Statement (PS18/8) setting out final rules and guidance...more

FCA Proposes New Guidance on Financial Crime Systems and Controls

The FCA is proposing to add a new chapter on insider dealing and market manipulation to its Financial Crime Guide. Key Points: ..The FCA proposes to add a new Chapter 8 to Part 1 of its Financial Crime Guide, outlining...more

Transforming Culture in Financial Services - The FCA Renews Its Approach

New FCA Discussion Paper demonstrates how the regulator’s thinking in relation to culture has evolved. Introduction - In Discussion Paper (DP) 18/2, the FCA has taken an unusual approach to a topic that has received...more

FCA Sets Expectations on Algorithmic Trading

The FCA has published a report, clarifying its expectations of firms that develop or use algorithmic trading strategies. On 12 February 2018, the FCA published a report on algorithmic trading compliance in wholesale...more

The (Potentially) Long Arm of the SMCR

Firms will need to consider whether any individuals in group entities require approval as Senior Managers. Introduction - Much has already been written on the proposed extension of the Senior Managers & Certification...more

FCA Publishes Long-Awaited Consultation Papers on the Extension of the SMCR

The FCA will take a proportionate approach, reflecting the diversity of firms within the proposed regime’s remit. On 26 July 2017, the FCA published its long-awaited Consultation Papers on the extension of the Senior...more

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