Legal Entity Identifier LEI

Of Relevance to: Most investment firms The concept of the need for, and the use of, a Legal Entity Identifier (“LEI”) for financial transactions was first proposed by the Financial Stability Board (“FSB”) in June 2012. Since that time, the regulatory use of LEIs has grown. A table produced by [...]

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SFTR – Transparency Requirements for UCITS and AIFs

SFTR – Transparency Requirements for UCITS and AIFs Of Relevance to: UCITS Management Companies and AIFMs Although the principal requirement under the Securities Financing Transactions Regulation (2015/2365) (“SFTR”) is the obligation on counterparties to securities financing transactions (“SFT”) to report details of any concluded SFTs to a trade repository, it [...]

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EMIR Review

Of Relevance to: Firms subject to European Markets Infrastructure Regulation The FCA has issued an EMIR update alert to inform us that the European Commission has published proposals to amend EMIR. Aspects of the proposals include the removal of the frontloading and backloading requirements – frontloading concerns the clearing of [...]

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Variation Margin

Of Relevance to: Firms trading in OTC derivatives A reminder that the EMIR Variation Margin Regulations (2016/2251) apply from 1 March 2017 in respect of uncleared OTC derivatives (although it was 4 February 2017 for those large players with uncleared derivatives in excess of €3 trillion). The Regulations require a [...]

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EMIR – Reporting to Trade Repositories Revision

Of Relevance to: Firms subject to EMIR The minimum details to be reported to a Trade Repository currently sit within Regulatory Technical Standards (“RTS”) Delegated Regulation 148/2013, with the format and frequency of trade reports contained in Implementing Technical Standards (“ITS”) Implementing Regulation 1247/2012. Both the RTS and the ITS [...]

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UCITS and AIFs: Transparency Requirements

Of relevance to: UCITS management companies and AIFMs UCITS and AIFs: Transparency Requirements A reminder to UCITS management companies and AIFMs that certain transparency obligations arising under the Securities Financing Transactions Regulation (“SFTR” – 2015/2365) apply from 13 January 2017 – see Regulatory Roundup 76. A SFT is defined as: [...]

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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 period ending 31 December in each calendar year; depending upon the value of AIFs under management, full-scope AIFMs will need [...]

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AIFMD: Annex IV Reporting Issues

Problems encountered by firms in meeting the demanding Annex IV reporting requirements (SUP 16.18) has led the FCA to issue a further set of Q&As to assist firms and which: Highlight aspects of AIFMD reporting where questions have been misinterpreted by some AIFMS; Identify where AIFMs have provided inconsistent responses [...]

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Connect vs. ONA

A reminder to firms that the FCA’s Online Notifications and Applications system (ONA), under which applications for Approved Persons, Variations of Permission etc. are submitted, will be largely replaced by a new online system – ‘Connect’ – from 1 October (although passport applications will remain on ONA). For the avoidance [...]

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