I wanted to make some brief comments on CP24/21 relating to investment research payment optionality for fund managers. The punchline is that the FCA is going to take the same line in liberalising the regime for fund managers as it has for investment managers of segregated portfolios. This will apply not just to unregulated AIFs

Jonathan Herbst (UK)
Market Watch 81 – the twist in the tail on transaction reporting
Market Watch 81 might on a first pass appear relatively uncontroversial in giving feedback on the FCA’s recent findings on transaction reporting. I would say that one should think again on this and suggest that there is a lot of food for thought here.
The basics on the Market Watch are set out in our…
The Financial Services and Markets Act 2023 (Consequential Amendments) Regulations 2024
On 7 November 2024, the Financial Services and Markets Act 2023 (Consequential Amendments) Regulations 2024 were laid before Parliament and published on legislation.gov.uk, along with an explanatory memorandum.
The Regulations make consequential amendments resulting from the commencement of provisions in (or made under) the Financial Services and Markets Act 2023 (FSMA 2023).…
Global Regulation Tomorrow Plus: UK PFOF
In the latest Global Regulation Tomorrow Plus episode, Jonathan Herbst, Hannah Meakin and Anita Edwards discuss some of the key issues concerning the UK regime for payment for order flow.
Listen to the episode here.
Updated AIFMD and NPPR guides
There are two methods which allow the marketing of alternative investment funds (AIFs) in the EU by alternative investment fund managers (AIFMs). The first method is a marketing “passport” which has been introduced by the Alternative Investment Fund Managers Directive (AIFMD) to allow AIFs to be marketed to professional…
UK PRA’s booking proposals – A step forwards or backwards?
In summer 2024, the Prudential Regulation Authority (PRA) published a Consultation Paper, CP11/24, on International firms: Updates to Supervisory Statement (SS5/21) and branch reporting. CP11/24 is key to understanding the booking models that the PRA will accept and reflects the debates which the branches of European banks have had in…
New Global Regulation Tomorrow Plus podcast – PRA CP11/24 International firms: Updates to SS5/21 and branch reporting
In our latest Global Regulation Tomorrow Plus podcast, Jonathan Herbst, Hannah Meakin and Anita Edwards discuss PRA Consultation Paper 11/24, which sets out proposals updating the regulator’s approach to international banks.
Listen to the episode here.
Let’s talk asset management: Episode 4 – New UK investment research rules
In Episode 4 of our podcast series ‘Let’s talk asset management’ Jonathan Herbst, Hannah Meakin and Anita Edwards discuss the UK Financial Conduct Authority’s final rules for a new option to pay for investment research.
Listen to the episode here.
The FCA’s research payment proposals – has the FCA done enough to make them workable?
In PS24/9 (Payment optionality for investment research) the FCA sets out final rules for a new option to pay for investment research and sets out its feedback to its earlier consultation in CP24/7. To remind everyone, the new option will exist alongside those already available, i.e., payments for research from a firm’s own resources and…
Public Offer Platforms (POPs) – Will they solve the problem?
- remove the current requirement for an FCA approved prospectus for offers of over £5 million provided the offer is made