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MiFID II Delayed

Of Relevance To Current MiFID firms and those entities falling under the MiFID II regime. MiFID II Delayed The implementation date of the MiFID II framework (both the Directive and […] [...]

Of Relevance To UCITS Management Companies; AIFMs of NURS; depositaries and custodians of UCITS schemes and AIFs. UCITS V The FCA has released Policy Statement PS16/2 “Implementation of the UCITS […] [...]

The Innovative Finance ISA

From 6th April 2016 the FCA rulebook will be changing to pave the way for the new Innovative Finance ISA (“IFISA”) which is part of the Government plan to allow […] [...]

Persons with Significant Control Register Obligation

A reminder that the obligation to maintain a Register of Persons with Significant Control (“PSC”) commences 6 April 2016 – see Regulatory Roundup 62 for background details; note that the […] [...]

Contract for Difference Products: FCA Concerns

Following a review of new client take-on procedures in a sample of ten firms that offered contract for difference (“CFD”) products, the FCA has published a ‘Dear CEO’ letter. We […] [...]

Fourth Money Laundering Directive: Proposed Amendments

As we know the UK (and other Member States) have until 26 June 2017 to implement the Fourth Money Laundering Directive (2015/849 – “4MLD”) into national law – see the […] [...]

Client Money: Loan-Based Crowdfunding CP16/4

Since the FCA assumed responsibility for the regulation of loan-based crowdfunding in April 2014, an investor’s money, subject to certain transitional provisions, held by a platform (P2P agreements) – both […] [...]

AIFMD: Passport Extension Update

Last July ESMA provided its advice and opinion to the European Parliament, the Council and the Commission on: the extension of the passport regime to non-EEA AIFMs; and the marketing […] [...]

EBA: Report on Investment Firms and Prudential Requirements

There has long been a recognition within the industry that the prudential requirements of investment firms arising out of the CRD IV framework were first and foremost designed for credit […] [...]

SEC Year End Obligations

Now that 2016 is firmly upon us, a number of United States regulatory filing deadlines come into view, particularly for firms with a 31 December fiscal year end (“FYE”). The […] [...]

Market Abuse: Delegated Regulation

The new market abuse regime deriving from Market Abuse Regulation 596/2014 (EU MAR) applies from 3 July 2016 – see Regulatory Roundup 70 for further details. The European Commission has […] [...]

SEC Office of Compliance Inspections and Examinations Examination Priorities for 2016

On 11 January 2016 the United States Securities and Exchange Commission (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) announced its 2016 Examination Priorities. As a reminder, OCIE serves as […] [...]

CRD 4: Remuneration and Proportionality

As may be recalled, the consultation paper issued by the EBA on ‘Sound Remuneration Policies’ (CP 2015/3) closed on 4 June 2015 – see Regulatory Roundup 65 for a summary. […] [...]

Senior Managers Regime

Last October HM Treasury issued a policy statement in which it advised: the Government considers it appropriate to extend the Senior Managers Regime (SMR) and the Certification Regime (CR) to […] [...]

Knowledge and Competence

Under Article 25(1) of MiFID 2 (2014/65) firms will be required to ensure (and to demonstrate to competent authorities on request) that persons giving investment advice or information about financial […] [...]

FAST Act Amendment to Disclosure Requirements

The President of the United States, Barack Obama, signed into law the Fixing America’s Surface Transportation (“FAST”) Act on 4 December 2015. The FAST Act included an amendment of the […] [...]

AIFMD: Annex IV Reporting

A reminder that the 31 December 2015 is a key reporting date for AIFMs: both small registered AIFMs and small authorised AIFMs are required to report annually with the reporting […] [...]

Thematic Review: Inside Information

The FCA has published its findings on yet another thematic review – this time looking at ‘Flows of Confidential and Inside Information’ (TR15/13). The review sample consisted of 16 mostly small […] [...]

Thematic Review: Wealth Management and Suitability

The FCA has published its thematic review of wealth management firms and private banks and the suitability of investment portfolios (TR15/12). This is not the first time the regulator has […] [...]

EMIR: Mandatory Clearing Regulation and Frontloading

The Commission Delegated Regulation (2015/2205) on the mandatory clearing of certain OTC derivative contracts through central counterparties (see Regulatory Roundup 67) under Article 4 of EMIR has now been published […] [...]

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