Imogen Garner (UK)

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Regulation Tomorrow Plus – UK IFPR series: Own funds requirements, fixed overheads requirements, and the K-factors for Assets Under Management and Client Orders Handled

The second podcast in our new mini-series focussing on the new UK Investment Firm Prudential Regime (or UK IFPR), brought to you as part of the Regulation Tomorrow podcast, covers own funds requirements, fixed overheads requirements, and the K-factors for Assets Under Management (K-AUM) and Client Orders Handled (K-COH). In addition, we have developed an … Continue Reading

Regulation Tomorrow Plus – UK IFPR series: An introduction to the UK IFPR and its application to different types of firm

The first podcast in our new mini-series focussing on the new UK Investment Firm Prudential Regime (or UK IFPR), brought to you as part of the Regulation Tomorrow podcast, provides an introduction to the UK IFPR and its application to different types of firm – CPMIs, commodities firms, exempt CAD firms and the application to … Continue Reading

The UK TPR is ending – what should EU firms do next?

On 1 September 2021 from 8:50am to 9:50am (UK time) we will be holding a webinar ‘The UK TPR is ending – what should EU firms do next?’ The UK provided a broad temporary permissions regime (TPR) which made it easy for EU investment firms to do business into the UK post Brexit. This regime … Continue Reading

FCA publishes final rules to strengthen investor protections in SPACs

Earlier this year the FCA issued consultation proposals (CP21/10) on changes to aspects of the Listing Rules that apply to special purpose acquisition companies (SPACs). A SPAC is a type of company formed to raise money from investors, which it then uses to acquire another operating business. The proposed changes were designed to provide an … Continue Reading

FCA sends Dear CEO letter to Portfolio Platforms

On 26 July, the Financial Conduct Authority (FCA) sent a Dear CEO letter to Portfolio Platforms, setting out reminders of their expectations in the following areas: Operational resilience; SUP 15 notification requirements; Transfer times; and Brexit In respect of operational resilience, the FCA reminds firms that they expect firms to invest in their systems to … Continue Reading

Commission confirms delay to the application of the SFDR RTS

On 23 July 2021, the European Commission published a letter (dated 8 July 2021) to the European Economic and Financial Affairs Council (ECOFIN) and the Council of the EU, confirming that the RTS application date, under the Sustainable Finance Disclosure Regulation ((EU) 2019/2088) (SFDR), has been delayed until 1 July 2022. This letter is the … Continue Reading

Treasury publishes response to Call for Evidence on Overseas Framework

On 22 July, the Treasury published the response to the Call for Evidence on the Overseas Framework, which was initially issued in December 2020. The Call for Evidence received 34 responses, with submissions from stakeholders from a range of sectors spanning banking, legal, wholesale, trading venues, insurance and trade bodies. Submissions also emanated from a … Continue Reading

SFDR draft RTS further delayed – what does it mean for firms?

Earlier this year, the European Supervisory Authorities (ESAs) published a final report containing draft regulatory technical standards (RTS) on the content, methodologies and presentation of sustainability-related disclosures under the empowerments set out in Articles 2a, 4(6) and (7), 8(3), 9(5) and 10(2) and 11(4) of the Sustainable Finance Disclosure Regulation (SFDR). At the time of … Continue Reading

FCA multi-firm review – Authorised fund managers’ assessments of their funds’ value

On 6 July 2021, the FCA set out the findings from its recent review concerning the processes used by different Authorised Fund Managers (AFMs) when they carry out assessments of value for the funds they operate. The FCA found that most of the 18 fund managers it had reviewed between July 2020 and May 2021, … Continue Reading

FCA CP21/21: Primary Markets Effectiveness Review

On 5 July 2021, the FCA published Consultation Paper 21/21: Primary Markets Effectiveness Review (CP21/21). In CP21/21 the FCA discusses the functioning of the listing regime so that it can better understand the purpose and value to both issuers and investors of listing. This will provide input to how the FCA can improve the listing … Continue Reading

MoU between HM Treasury and the Monetary Authority of Singapore

On 30 June 2021, the Chancellor announced a new financial partnership between the UK and Singapore. The Partnership is backed up by a non-legally binding memorandum of understanding (MoU) which aims to reduce frictions for firms serving UK and Singapore markets. Under the Partnership, the UK and Singapore will explore opportunities for greater financial cooperation, … Continue Reading

FCA review finds weaknesses in some ‘host’ authorised fund management firms’ governance and operations

On 30 June 2021, the FCA published the findings of its multi firm review into the activities of host authorised fund manager firms (AFMs). The FCA reports that it found that whilst some firms were operating well, others are not. The FCA found weaknesses in governance structures, conflicts of interest management and operational controls.  The … Continue Reading

Guidelines on stress test scenarios under the MMF Regulation

On 29 June 2021, the European Securities and Markets Authority (ESMA) published guidelines that apply in relation to Article 28 of the Money Market Funds Regulation and establish common reference parameters for the stress test scenarios to be included in the stress tests conducted by money market funds (MMFs) or managers of MMFs in accordance … Continue Reading

FCA consultations on enhancing climate-related disclosures

On 22 June 2021, the FCA published the following: Consultation Paper 21/17: Enhancing climate-related disclosures by asset managers, life insurers, and FCA-regulated pension providers (CP21/17). Consultation Paper 21/18: Enhancing climate-related disclosures by standard listed companies and seeking views on ESG topics in capital markets (CP21/18). Background In November 2020, the Government published a Roadmap towards … Continue Reading

Webinar – Financial services academy: Mastering the fundamentals

Date: 7 July 2021 Time: 08:30am – 10:00am GMT We are pleased to invite you to our inaugural financial services academy. The academy will take the form of a series of online webinars that are aimed at up-and-coming in-house regulatory lawyers and compliance professionals, as well as anyone in need of a refresher. During the … Continue Reading

Episode 8 of the Regulation Tomorrow Podcast – out now

Episode 8 of the Regulation Tomorrow Podcast is available now to stream and download on your usual podcast platform. In this month’s episode we receive an update on Brexit from Jonathan Herbst, as he discusses the future of financial services in the UK with Hannah Meakin. We speak to Imogen Garner, Iona Wright and Daniel … Continue Reading

Independent expert group appointed to advise Government on standards for green investment

On 9 June 2021, the Government announced the appointment of a Green Technical Advisory Group (GTAG). The GTAG will provide independent, non-binding advice to the Government on developing and implementing a Green Taxonomy in the UK context. This includes advising on: Approach to developing a UK Green Taxonomy that is usable and practicable for financial … Continue Reading

EU Taxonomy Climate Delegated Act

On 4 June 2021, there was published on the European Commission’s website: Adoption of the EU Taxonomy Climate Delegated Act (not in force until it is published in the Official Journal). Impact assessment accompanying the EU Taxonomy Climate Delegated Act. Summary of the impact assessment accompanying the EU Taxonomy Climate Delegated Act. Opinion of the … Continue Reading

NGFS publishes the second vintage of climate scenarios for forward looking climate risks assessment

On 7 June 2021, the Network for Greening the Financial System (NGFS) announced the following new documents: A new set of climate scenarios. In this second vintage, the NGFS scenarios have been brought up to date, including by incorporating countries’ commitments to reach net-zero emissions. They have also been enriched with an expanded set of … Continue Reading

TCFD public consultation

On 7 June 2021, the Task Force on Climate-Related Financial Disclosures (TCFD) issued two documents for public comment: Proposed Guidance on Climate-related Metrics, Targets, and Transition Plans. When the TCFD issued its Final Recommendations in 2017, it was aware of the limitations of reporting certain metrics as well as the nascency of climate-related reporting at … Continue Reading

FCA statement – Publication of costs and charges data by workplace personal pension providers

On 3 June 2021, the FCA issued a statement on its website concerning the publication of costs and charges data by workplace personal pension providers. In the statement the FCA refers to its earlier consultation paper on requirements for workplace personal pension scheme providers to publish costs and charges data, and the resulting policy statement … Continue Reading

PRA PS11/21 – Strengthening accountability: Temporary, long-term absences

On 1 June 2021, the PRA published Policy Statement 11/21 “Strengthening accountability: Temporary, long-term absences” (PS11/21). In PS11/21 the PRA provides feedback to responses to chapter 2 of FCA Consultation Paper 20/23 “Quarterly Consultation Paper No. 30’ (CP20/23). In chapter 2 of CP20/23 the FCA and PRA jointly proposed their expectations regarding temporary, long-term absences … Continue Reading
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