On 1 September 2020, the Prudential Regulation Authority (PRA) published a Dear CEO letter from Sam Woods, Deputy Governor and CEO of the PRA to remind firms to be operationally ready for the Temporary Permissions Regime (TPR).
The TPR is due take effect at 11pm on Thursday 31 December 2020, which is the point at which the transition period agreed as part of the Withdrawal Agreement between the UK and European Union (EU) will end.
Firms that have submitted a valid Notification or submitted a Part 4A application (and not subsequently withdrawn it) will automatically enter the TPR. During the TPR in scope firms will have a deemed Part 4A permission to carry on their existing activities for up to a maximum of three years from the end of the transition period[1]. Where firms are passporting and already have a top-up permission, they will need to obtain a deemed variation of that permission.
In order to support firms in relation to the TPR, the PRA published updated information on its website on 1 September 2020 summarising its approach to the TPR and the key requirements for UK branches of firms. Please see our related article summarising this here.
The PRA has asked firms to read the information on its website and take all appropriate actions to ensure that they are fully operationally prepared before entering the TPR. It will continue to communicate with firms in the run up to the TPR taking effect and will be checking in with firms to understand their progress and preparedness.
[1] Subject to HM Treasury’s power to extend the duration of the regime by increments of twelve months.