Photo of Jonathan Herbst (UK)

Jonathan Herbst (UK)

To all of our global readers we would like to take this opportunity to wish you all a Merry Christmas and a Happy New Year.

We will resume posting material following the festive period on 7 January 2025 although if there are any significant developments we will endeavour to provide an update.

The FCA is producing a lot of consultations at the moment and it is easy to miss the significance of some of them. However, CP 24/28 is an important one for all firms. We have done a blog on its main contents but I would flag some key points.

First, the new incident reporting obligations

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

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).

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

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