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IOSCO Consults on Regulation of ESG Data and Ratings Providers

On 26 July 2021, the Board of the International Organization of Securities Commissions (IOSCO) published a consultation report (the Report) that proposes a set of recommendations to mitigate risks flowing from activities of...more

UK to Adopt a New SPAC Listing Regime From 10 August 2021

The revised criteria allow UK-listed SPACs to avoid a suspension of their shares when announcing a de-SPAC deal. The UK, acting through the Financial Conduct Authority (FCA), will implement a new SPAC listing regime from...more

FCA Consults on Post-Brexit Changes to PRIIPS Regulation

UK rules will diverge from the much-criticised EU framework. On 20 July 2021, the FCA published a Consultation Paper (CP21/23) on amending the UK PRIIPs Regulation. The FCA has long held concerns about the PRIIPs...more

FCA Seeks to Improve Quality of ESG Fund Disclosures

FCA has published guiding principles on the design, delivery, and disclosure of ESG and sustainable investment funds. On 19 July 2021, the FCA published a letter sent to chairs of authorised fund managers, which sets out...more

ESMA Publishes Guidance on SPACs

ESMA warns against investor protection risks and provides guidance on expected disclosures. On 15 July 2021, ESMA published a statement on the prospectus disclosure and investor protection issues raised by special...more

Private Bank Briefing – June 2021

The latest edition of our Private Bank Briefing provides a roundup of legal and compliance issues impacting private banks and their clients from Q2 2021. In this edition, we cover sustainable finance developments, the...more

FCA Proposes New Climate-Related Disclosure Regime

The FCA is proposing a disclosure regime for asset managers, life insurers, and pension providers. On 22 June 2021, the FCA published a Consultation Paper (CP21/17) on introducing climate-related financial disclosure...more

Climate (and ESG) Risk: The Growing Focus on Board Accountability

Board members are expected to have adequate knowledge and understanding of climate-related and ESG risks. Legislators and regulators around the world have long recognised that one of the most effective ways to drive change is...more

The European Commission Unveils New Sustainable Finance Package

The package focuses on material sustainability reporting and disclosure obligations, as the EU looks to direct capital toward sustainable activities. On 21 April 2021, one day prior to Earth Day and a US-led global...more

FCA Consults on Rule Changes to Accommodate SPACs

Proposed changes to the UK Listing Rules would allow certain SPACs to avoid a listing suspension. Key Points: ..The FCA is proposing to amend its rules so that SPACs meeting certain conditions and disclosure...more

EBA Consults on Prudential Disclosures on ESG Risks

The EBA consultation paper calls for the implementation of a Green Asset Ratio to measure banks’ sustainability performance. Regulators and sustainability-conscious investors increasingly expect banking institutions in...more

FCA Consults on Changes to UK MiFID Conduct and Organisational Requirements

The consultation proposes changes to rules on research and best execution reporting. On 28 April 2021, the FCA published a Consultation Paper (CP21/9) on proposed changes to UK MiFID relating to research unbundling and...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

ESG and Cryptocurrency: Considerations for Market Participants

For market participants pivoting toward ESG and digital assets, weighing the issues at the crossroads of these two megatrends is critical. The huge rise in popularity of Bitcoin - and the growing interest by mainstream...more

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

CFTC Takes Action With New Climate Risk Unit

The CFTC continues to demonstrate a commitment to using its regulatory mandate to combat climate change risks to the US financial system. On March 17, 2021, the Commodity Futures Trading Commission (CFTC) announced the...more

ESG Disclosures Under the EU Taxonomy Regulation and CRR: Latest Developments

ESMA and the EBA advise on KPIs for transparency on institutions’ environmentally sustainable activities, and the EBA consults on prudential disclosures of ESG risks under the CRR. On 26 February 2021, both the European...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

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

Benchmarks: Delegated Acts on ESG Disclosures Published and Transitional Period for Third Country Benchmarks Extended

Three delegated acts that supplement the EU Benchmarks Regulation will come into force on 23 December 2020. The long-awaited delegated acts (Delegated Acts) required by Regulation (EU) 2019/2089 (the Low Carbon Benchmarks...more

FCA Considers Establishing ESG Guiding Principles

FCA director highlights areas of concern in relation to ESG reporting and provides recommendations. Richard Monks, Director of Strategy at the UK Financial Conduct Authority (FCA), recently delivered a speech on the...more

US Department of Labor Puts ESG Investing on Ice

In its finalized rule amending ERISA, the DOL makes financial factors paramount in a fiduciary’s responsibility to investors. On October 30, 2020, the US Department of Labor (DOL) published Financial Factors in Selecting...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

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