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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

HM Treasury Kicks Off Financial Services Future Regulatory Framework Review

Call for evidence on regulatory cooperation marks the first phase of the planned review. The Chancellor announced in the Spring Statement that HM Treasury would undertake the Financial Services Future Regulatory Framework...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

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

Brexit and Financial Services — UK Equivalence Decisions

HM Treasury has published draft legislation that will allow the UK to make timely equivalence decisions in relation to the EU. Key Points: ..Post-Brexit, HM Treasury will take on the role of making equivalence decisions...more

Outsource Service Providers to the Financial Services Industry - A Growth Sector for Buyout Firms

Technology outsourcing by financial institutions (FIs) has increased in recent years as FIs look to the latest innovations to improve their day-to-day business processes and to reduce costs. FIs outsource key functions to a...more

Brexit and Financial Services - Temporary Permissions

The UK’s temporary permissions regime appears to be a helpful concession for inbound firms, but there are some hidden challenges. Key Points: ..The UK regulators have set out further details of the rules they propose...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

Brexit and Financial Services — Onshoring MiFID II

Latham & Watkins demystifies the process for onshoring the MiFID II regime, and outlines the key changes for firms operating in the UK. Key Points: ..The onshoring process is designed to preserve the status quo as much...more

UK Cryptoassets Taskforce Publishes its Final Report

The Taskforce’s final report outlines the UK’s policy and regulatory approach to crypto-assets and distributed ledger technology in financial services. Key Points: ..The Report provides an overview of crypto-assets and...more

A New Sheriff in Town? UK MPs Call for Regulation of “Wild West” Crypto-assets

The House of Commons Treasury Committee has published its recommendations for the regulation of crypto-assets in the UK. Key Points: ..The House of Commons Treasury Committee has proposed that the UK government should...more

Private Bank Briefing: Issues Impacting the Private Bank Sector

The FCA published a Discussion Paper on a duty of care and potential alternative approaches (DP18/5) on 17 July 2018. The FCA is exploring whether there should be a duty of care in the financial services sector. It is...more

Consumer Credit Update

This update takes a look at the FCA’s Interim Report and its initial views relating to the review of the provisions of the Consumer Credit Act 1974 (CCA), which show early signs of a more pragmatic approach to regulation than...more

FCA Sets Out Stance on Cross-Border Booking Arrangements

The “Dear CEO” letter underlines the FCA’s open and pragmatic approach in the context of Brexit. The FCA has published a “Dear CEO” letter to firms, advising them of its position in relation to the use of cross-border...more

First Details of Brexit Temporary Permissions Regime Published — Key Questions Answered

UK regulators expand on plans to smooth the transition for inbound passporting firms in the event of a “no deal” Brexit. Overview - HM Treasury published draft legislation on 24 July 2018 to establish a temporary...more

FCA Speaks Out on the Ethics of Big Data

FCA Chair hints that new regulation addressing data ethics in the FinTech space may be on the horizon. Will societies of the future be ruled by algocracy, in which algorithms decide how humans are governed? ...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

Private Banking Newsletter: Issues Impacting the Private Bank Sector

The FCA’s Business Plan for 2018/19, published on 9 April 2018, outlined key priorities for the upcoming year. Although the Business Plan revealed that the FCA’s Brexit-related workload will mean a dearth of new initiatives,...more

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