On July 1, 2020, FINRA issued guidance to member firms on compliance with FINRA Rule 2210 (“Rule 2210”)) on the marketing of private placements to retail investors. These private placements are typically conducted under Rules 504, 506(b) or 506(c) of Regulation D under the Securities Act of 1933, as amended, as “safe harbors” that permit
July 2020
SEC Proposes Amendments to Increase Reporting Threshold for Institutional Investment Managers
On July 10, 2020, the Securities and Exchange Commission (“SEC”) proposed amendments to amend Form 13F to update the reporting threshold for institutional investment managers and certain other changes. This marks the first time that the reporting threshold would be updated since its introduction more than 40 years ago.
Pursuant to Section 13(f) of the…
Amending the transitional period for third country benchmarks in the UK
On 22 July 2020, HM Treasury issued a policy paper explaining the government’s rationale for extending the transitional period for third country benchmarks under the UK Benchmarks Regulation to 31 December 2025.
The EU Benchmarks Regulation (BMR) has directly applied in the UK since 1 January 2018. To ensure that the existing regime…
FCA letter to Remuneration Committee Chairs
On 22 July 2020, the FCA published a letter it had sent to Remuneration Committee Chairs. In the letter the FCA sets out its findings and observations from the 2019/20 remuneration round and how it plans to assess firms’ remuneration policies and practices throughout 2020/21.
Among other things the letter notes that during this time…
Non-systemic UK banks: The PRA’s approach to new and growing banks
On 22 July 2020, the PRA published Consultation Paper 9/20 ‘Non-systemic UK banks: the PRA’s approach to new and growing banks’ (CP9/20).
In CP9/20 the PRA sets out its proposed approach to supervising new and growing non-systemic UK banks (collectively referred to as ‘banks’). All the proposals are clarifications of the PRA’s current…
FCA consults on the delay to the implementation of the European Single Electronic Format
On 22 July 2020, the FCA published Consultation Paper 20/12: Delay to the implementation of the European Single Electronic Format (CP20/12).
In summary, the FCA’s proposals in CP20/12 are as follows:
- The requirement for all issuers to publish their annual financial reports in XHTML web browser format, replacing the current PDF format, be
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FCA Feedback Statement 20/12: Intergenerational differences: summary of responses and next steps
On 22 July 2020, the FCA published Feedback Statement 20/12: Intergenerational differences: summary of responses and next steps (FS20/12).
Last summer the FCA published Discussion Paper 19/2: Intergenerational differences in which it wanted to test its understanding of the issues different generations face and identify where, if any, potential action could help the…
Commission adopts Delegated Regulations supplementing the BMR
On 22 July 2020, the European Commission adopted the following Delegated Regulations supplementing the Benchmarks Regulation on sustainable finance issues:
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The EBA observes an increase in high earners in 2018 and the persistence of differences in remuneration practices across the EU
On 22 July 2020, the European Banking Authority published its report on benchmarking of remuneration practices in EU banks for the financial years 2017 and 2018 and high earners data for 2018. The data shows that in 2018, the number of high earners in EU banks receiving a remuneration of more than EUR 1 million…
EBA is looking into ways to reduce reporting costs
On 22 July 2020, the European Banking Authority (EBA) issued a questionnaire addressed to all European banks and a call for case studies to collect evidence on reporting costs as well as industry views on ways to reduce such costs and make supervisory reporting more efficient.
The EBA is mandated by Article 430(8)…