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The MAR Review — ESMA’s Final Report

ESMA advises the European Commission to consider some, but not all, of ESMA’s original proposals — and gives guidance on pre-hedging and market soundings along the way. Key Points: ..Pre-hedging / front running: ESMA...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

MAR and Sustainable Investing/ESG

ESG and the reasonable investor test under MAR. Background - Historically, “profit maximisation” has been regarded as the sole (or predominant) objective for investors. Today, however, an ever-increasing proportion of...more

CFTC Report: Climate Change Threatens Stability of US Financial System

A watershed CFTC report highlights the dangers of climate change to the US economy, and provides a broad risk-mitigation roadmap. On September 9, 2020, the US Commodity Futures Trading Commission’s (CFTC’s) Climate-Related...more

EU Regulatory & Antitrust Monitoring on Sustainability Newsletter - September 2020

Welcome to the inaugural issue of the EU Regulatory & Antitrust Monitoring on Sustainability newsletter. The September issue features six key takeaways from the past month to which companies and investors operating in the EU...more

HM Treasury Policy Statement Addresses Pressing Concerns With PRIIPs Regulation

The UK government has proposed amendments to the UK PRIIPs regime with performance information in the KID to differ from the EU “performance scenario” requirement. On 30 July 2020, HM Treasury published a policy statement...more

European Commission Proposes Changes to MiFID II Due to COVID-19

Many of the wide-ranging amendments address the perceived barriers MiFID II introduced in capital markets and are likely to be welcomed by industry. Key Points: ..The amendments aim to remove administrative burdens that...more

Dear CEO: UK Banks and Insurers Should Embed Approaches to Managing Climate Change Risks by End-2021

The PRA expands its supervisory expectations for firms on managing climate-related financial risk — publishing a Dear CEO guidance letter. On 1 July 2020, the PRA published guidance in the form of a Dear CEO letter to...more

The CFRF Guide to Climate-Related Financial Risk Management

The CFRF’s practical Guide encourages UK regulated financial services firms to take active steps to manage climate-related financial risks. Background - On 29 June 2020, the Climate Financial Risk Forum (CFRF) launched...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

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

ESG in European Private Equity: The Effects of COVID-19

Increasing interest in ESG issues presents an opportunity for sponsors to re-evaluate their existing ESG strategies. The COVID-19 pandemic continues to present unprecedented challenges for private equity firms and their...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

UK Delays Decision on Adopting EU Sustainable Finance Taxonomy

The delay may complicate the regulatory landscape for sustainable finance as the EU moves toward a standardized classification system.  The UK government (government) has delayed a decision on whether it will adopt the...more

Staying Inside - FCA’s New Guidance on Market Conduct During COVID-19

New guidance for issuers and market participants on capital raising events and alternative working arrangements, and additional time allowed for filing half-yearly financial reports. On 27 May 2020, the FCA published its...more

European Commission Publishes Draft Delegated Regulations on ESG Disclosures in Benchmarks

The three draft delegated regulations set out sustainability criteria and ESG disclosure requirements for benchmarks provided in accordance with the EU Benchmarks Regulation. Key Points: ..The measures follow amendments...more

New Draft Regulatory Technical Standards Under the EU Benchmarks Regulation

The draft RTS introduce new, potentially more onerous obligations on the administrators of all categories of benchmarks. Key Points: ..The draft RTS contain new guidance that makes clear who is responsible for which...more

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

On 17 March 2020, the FCA published a new webpage providing information on its expectations of firms’ response to the coronavirus. It will update the webpage over the coming weeks and expects to adapt its guidance...more

FCA Proposes New Rules on Climate-Related Disclosures by Listed Issuers

The FCA is moving towards formalising issuers’ compliance with the TCFD recommendations. Key Points: ..The FCA is proposing that premium listed commercial companies will need to disclose how they have implemented the...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

MiFID Refit - Commission Consults on Review of MiFID II Framework

The consultation provides a key opportunity for market participants to provide feedback on the regime. Key Points: ..The consultation covers a broad range of MiFID topics and, while framed as a questionnaire, contains...more

ESMA Provides Its Input on the BMR Review

ESMA has published its response to the Commission’s review of the BMR, which gives an indication of the areas where changes to the regulation are more likely to be made. Key Points: ..ESMA’s response to the European...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

Key Takeaways from ESMA’s recent MiFID Transparency Consultation Papers

ESMA’s consultation papers on MiFID non-equities SI and equities transparency regimes propose important changes. Key Points: ..ESMA’s recent consultation papers on the MiFID transparency regime raise queries and make...more

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