Key Regulatory Topics: Weekly Update 14 July – 20 July 2023
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This week saw further progress on the UK’s Smarter Regulatory Framework, including new webpages on the FCA’s Rule Review Framework and the FCA’s work on retained financial services EU law. The Chairs of the Financial Services Regulatory Initiatives Forum also provided an update on the Regulatory Initiatives Grid. On the cost of living crisis, there were various publications from the FCA, ICO and the Treasury Committee on savings accounts and rates. Over the channel, EU negotiators reached agreement on the proposals in relation to instant credit transfers, and on the sustainable finance side the EBA and IOSCO have respectively issued publications on gathering ESG and climate-related data from institutions, and carbon capital markets
ICO and FCA letter to UK Finance and Building Societies Association on how firms can support savings customers
On 18 July, the FCA and ICO published a joint letter to UK Finance and the Building Societies Association on data protection and effective communications to savings customers. The letter clarifies the types of communications firms can provide without breaching data protection and electronic communications regulations, which contain certain marketing restrictions. Firms may provide neutral, factual information about the interest rate and terms of the customer’s savings product, the interest rate and terms of other available savings products, and the options for moving to another product. However, firms must still comply with data protection requirements when using customer information. The FCA will be paying close attention to firms’ engagement strategies to support their savings customers to achieve good outcomes and will report on this at the end of July.
Treasury Committee publishes responses from the ‘big four’ high street banks and the FCA on savings rates
On 18 July, the Treasury Committee published the responses it received from the ‘big four’ high street banks and the FCA on savings rates. In summary, the banks had been asked if they believe their savings rates provide ‘fair value’ and whether customer inertia is being exploited. The Committee had also separately written to the FCA, asking the FCA to give examples of a bank changing its rate as a consequence of regulatory challenge, querying how ‘fair value’ will be judged, including in the context of the Consumer Duty, and asking how and when the FCA would take action if banks do not make enough effort to encourage savers to switch to higher rates. The FCA confirmed that it expects firms to ensure customers are informed of available rates across their product set and how they may benefit from switching.
FCA statement on its supervisory approach to certain mortgage disclosure requirements.
On 14 July, the FCA published a statement on temporary regulatory forbearance on MCOB 7.6.28R, which requires firms to give a borrower a prescribed, personalised disclosure before varying their mortgage contract. The forbearance will support the implementation of the Government’s Mortgage Charter, which introduced an exemption from the MCOB affordability assessment requirements, where borrowers reduce their capital repayments for up to six months, or fully or partly reverse a term extension within six months. Where such a reduction or reversal is being made, some firms’ systems might not yet allow them to meet the disclosure requirement. If this is the case, firms should provide as much of the required disclosure as possible, in a durable medium, and should make clear the implications and risks associated with the change and take all reasonable steps to support the customer. Notwithstanding this forbearance, the rules remain in force, and compliance with the relevant MCOB rules is expected as soon as possible, and in any event by the end of January 2024.
FCA consultation on financial promotions on social media
On 17 July, the FCA published a consultation on guidance on how the FCA financial promotion requirements apply to promotions on social media. The FCA explains that since its guidance FG15/14 was issued, the social media landscape has changed. Social media has become an increasingly important marketing tool for firms, with YouTubers and streamers becoming a major source of financial promotions. As such, the FCA is consulting on a new, standalone guidance for financial promotions on social media to reflect the current landscape. The deadline for comments is 11 September.
Financial Crime and Sanctions
ESMA report on suspicious transaction and order reports
On 17 July, ESMA published a report on Suspicious Transactions and Order Reports (STORs). The report provides an overview of how STORs are used across different jurisdictions in the context of the detection and investigation of market abuse, and how their use has evolved over time. ESMA notes that the figures are generally consistent and no major changes can be detected across 2021 and 2022. In addition, NCA notification numbers and other indicators are stable and point wards similar results. In recognition of the effect of Brexit, ESMA has tried, where possible, to include statistics both with and without the UK to provide a comprehensive view. ESMA will continue to monitor STORs and may issue a report next year covering 2023.
Treasury Committee publishes government’s response to regulating crypto report
On 20 July, the Treasury Committee published the government’s response to its report on regulating crypto (published in May). The report called for consumer trading in unbacked crypto to be regulated as gambling. The Committee had concluded that given the price volatility and the risk of losses, retail trading in unbacked crypto more closely resembles gambling than a financial service and should be regulated as such. In its response, however, the government disagreed with the Committee’s recommendation, for reasons including the belief that gambling regulation of unbacked crypto would not address the relevant risk factors and that such regulation would limit the UK’s ability to make it safer, and capitalise on the potential benefits. The government did however confirm its commitment to addressing the risks associated with unbacked crypto.
FCA launches permanent Digital Sandbox
On 20 July, the FCA announced that its Digital Sandbox will be available permanently from 1 August, opening up the platform to an even broader range of innovative businesses, start-ups and data providers. Following two successful pilots, the FCA has decided to make the Sandbox permanently available so participants of the Sandbox will have permanent access to: (i) high-quality datasets and APIs; (ii) robust data security protection; (iii) a collaborative platform; and (iv) an observation deck. From 1 August, firms will be able to apply for the permanent Digital Sandbox under various themes such as banking, investment, pension, and wholesale sell-side. Applicants will be assessed against the following criteria: (a) in scope; (b) genuine innovation; (c) consumer benefit; (d) readiness; and (e) need for support. The FCA explains that the approval process will take a maximum of 4 weeks. More information on how to apply and what the FCA are looking for will be made available from 1 August.
FSB finalises global regulatory framework for cryptoasset activities
On 17 July, the FSB published its global regulatory framework for cryptoasset activities to promote the comprehensiveness and international consistency of regulatory and supervisory approaches. The framework is based on the principle of ‘same activity, same risk, same regulation’, and seeks to ensure cryptoasset activities and stablecoins are subject to consistent and comprehensive regulation, commensurate to the relevant risks, while supporting responsible innovation. It consists of two sets of recommendations: (i) high-level recommendations for the regulation, supervision and oversight of cryptoasset activities and markets; and (ii) revised high-level recommendations for the regulation, supervision, and oversight of “global stablecoin” arrangements. The FSB and standard-setting bodies will continue to coordinate the promotion of globally-consistent regulation.
Council of the EU and the EP reach a provisional agreement on new rules to improve European capital markets and strengthen investor protection in the EU
On 20 July, the Council of the EU announced that negotiators from the Council and the EP had reached a provisional agreement on new rules to improve European capital markets and strengthen investor protection in the EU. The new rules amend both the AIFMD and the UCITS framework in relation to delegation arrangements, liquidity risk management, supervisory reporting, depositary and custody services and AIF loan origination. Negotiators agreed to enhance the integration of asset management markets in Europe and to modernise the framework for key regulatory aspects and the availability of liquidity management tools, with new requirements relating to the activation of these instruments. Negotiators also reached a provisional agreement on an EU framework for funds originating loans and enhanced rules for delegation by investment managers to third parties. Other key components of the agreement include: (i) enhanced data sharing and cooperation between authorities; (ii) new measures to identify undue costs that could be charged to funds, and hence their investors; and (iii) new measures to prevent possible misleading names to better protect investors. Before the agreement can be formally adopted, it needs to be confirmed by the Council and the EP. On the same day, the EC published a press release welcoming the agreement.
Commission report on the prudential and economic adequacy of the MMF Regulation
On 20 July, the EC published a report on the adequacy of the MMF regulation on money market funds from a prudential and economic point of view. The report shows that the MMF Regulation successfully passed the test of liquidity stress experienced by MMFs during the COVID-19 related market turmoil of March 2020, the recent interest rate increases, and related financial asset re-pricing. These observations indicate that the safeguards in the MMF Regulation have been working as intended. The report found that while the MMF Regulation has significantly strengthened the regulatory framework for MMFs in the EU, there were also some shortcomings which require further assessment, which show that there could be scope to further increase the resilience of EU MMFs - notably by decoupling the potential activation of liquidity management tools from regulatory liquidity thresholds.
ESMA publishes 2022 UCITS and AIFMD sanction reports
On 18 July, ESMA published its 2022 reports on use of sanctions under the UCITS Directive and AIFMD. The reports set out an overview of the applicable legal framework, and information on the penalties and measures imposed by NCAs from 1 January 2022 to 31 December 2022. Besides a limited number of NCAs issuing an increasing number of sanctions, the level of sanctions issued at national level remains stable and generally low, in particular when it comes to penalties. Moving forward, ESMA will continue its work to foster supervisory convergence in terms of the application of the UCITS Directive and AIFMD, and to develop a common EU outcome-focused supervisory and enforcement culture.
Markets and Markets Infrastructure
ESMA proposes revised technical standards on anti-procyclicality margin measures
On 19 July, ESMA published a final report proposing measures to harmonise CCP policies and procedures for selecting, assessing and reviewing anti-procyclicality (APC) margin measures. ESMA’s proposals include targeted changes to the existing RTS in order to better mitigate the effects of big step margin changes on clearing members and clients, as well as to limit the spread of liquidity stress to other parts of the financial system. The proposed revisions focus on previous ESMA requirements and guidance but do not make new prescriptive proposals in areas where further work is expected at the international level, such as margin transparency. The revised RTS also aim to provide more granularity on the design and use of specific APC tools, while ensuring sufficient flexibility for the CCPs to adapt to market situations. The report will be submitted to the EC for endorsement within three months in the form of an amending Delegated Regulation. Following their adoption, the RTS would then be subject to the non-objection of the EP and the Council.
FMSB consults on the application of a model risk management framework to electronic trading algorithms
On 18 July, the FMSB published a transparency draft statement of good practice for the application of a model risk management framework to electronic trading algorithms (referred to as ‘Algos’). The statement sets out the views of market practitioners on how the wholesale markets industry can apply their existing model risk management frameworks in a proportionate way to Algos. The statement considers: (i) key factors in determining if a method used in an Algo constitutes a model; (ii) factors influencing the risk-tiering assigned to a model used in Algos, and the impact of mitigating controls in reducing the residual risk of a model; (iii) key features of model testing for Algos; (iv) tailoring models deployed in Algos to the context and purpose for which they are deployed, focusing on model methodology and input accuracy, staffing and ongoing performance monitoring of outputs; and (v) the treatment of material changes to models deployed in Algos from a validation and documentation perspective. FMSB invites comments on this transparency draft, the deadline for which 22 September.
FCA and PRA consult on margin requirements for non-centrally cleared derivatives
On 18 July, the FCA and PRA published a consultation paper on changes to the UK bilateral margining requirements under UK EMIR. The regulators are proposing to extend the temporary exemptions for single-stock equity options and index options from the UK bilateral margining requirements from 4 January 2024 until 4 January 2026. The consultation paper also sets out a proposed approach to model pre-approval in relation to bilateral initial margin models, whereby the regulators will not implement a supervisory pre-approval requirement for using initial margin models. This is on the basis that the UK regime already includes detailed and prescriptive modelling requirements, the UK framework already allows supervisors to review compliance, and the PRA already engages actively with firms and model developers. The deadline for comments is 18 October.
Commission consultation on amending implementing decision on Australian equivalence under EMIR
On 17 July, the EC published a consultation on a draft Implementing Decision amending Implementing Decision (EU) 2016/2272 on the equivalence of financial markets in Australia in accordance with EMIR, to update the Decision with an additional Australian financial market which has obtained authorisation from ASIC to trade in derivatives. The deadline for comments is 14 August.
FCA updates webpages on UK EMIR clearing obligation
On 17 July, the FCA updated various webpages relating to the UK EMIR clearing obligation and the UK EMIR margin requirements. The webpages have been updated to reflect the extension of the exemption for pension scheme arrangements from the UK EMIR clearing obligation by two years until 18 June 2025, and the extension of the Temporary Intragroup Exemption Regime by three years until 31 December 2026. Accordingly, UK firms that currently benefit from these exemptions may continue to do so. Additional information on the clearing exemption for pensions scheme arrangements and intragroup exemptions from the clearing obligation and margin requirements has been published on the relevant webpages.
ESMA updates Q&As on the Securitisation Regulation
On 14 July, ESMA published an updated version of its Q&As (dated 13 July) on the Securitisation Regulation. ESMA has added and modified questions on the following topics: (i) disclosure requirements and templates; (ii) Annex 2: Underlying Exposures (Residential Real Estate, Commercial Real Estate, Corporate, Leasing and Esoteric); (iii) Annex 4: Underlying Exposures – Corporate; (iv) Annex 8: Underlying Exposures – Leasing; (v) Annex 9: Underlying Exposures – Esoteric; and (vi) Annexes 12 and 13: Investor Reports. The Q&As were last updated in November 2021.
Commission adopts Delegated Regulation extending transitional period for third-country benchmarks under BMR
On 14 July, the EC adopted a Delegated Regulation extending the transitional period laid down for third-country benchmarks used by supervised entities in Article 51(5) of the BMR to 31 December 2025. The EC found that a majority of third country benchmark administrators have not taken the necessary steps to prepare for the end of the original transition period, meaning EU supervised entities would no longer have access to most of the world’s benchmarks. This would put EU entities at a competitive disadvantage, and would pose potential risks to financial stability. The extension aims to avoid those risks and provide market players with legal certainty and ensure business continuity. The Delegated Regulation will not enter into force until the third day following it is published in the OJ.
Payment Services and Payment Systems
Negotiating positions of EU institutions on proposed Regulation on instant credit transfers in euro published
On 17 July, the Council of the EU published an information note containing a table comparing the positions of the EC, the EP and the Council of the EU on the proposed Regulation amending the SEPA Migration Regulation and the Cross-Border Payments Regulation as regards instant credit transfers in euro. The proposed Regulation is part of the initiative to promote the provision and uptake of instant payments in line with the Eurosystem’s retail payments strategy, to increase consumer choice and foster innovation, safety and open strategy autonomy. The positions have been published ahead of the commencement of the trilogue phase.
PSR response to its call for views on its first annual review of Specific Direction 12
On 14 July, the PSR published a response to its call for views on its first annual review of Specific Direction 12 (SD12), together with stakeholder submissions. The PSR concluded that SD12 has worked well to ensure that LINK continues to meet its commitment to maintain a broad geographic spread of free-to-use (FTU) ATMs, and meet users’ needs, and should remain in place. However, the PSR did identify four areas for improvement: (i) applying the Defined Radius approach in practice, including how best to take into account economic activity; (ii) the transparency of LINK’s published data on Protected ATM coverage, including decision-making on ATM replacement and updates to the Protected ATM list; (iii) the transparency of LINK’s decision-making on setting interchange fees; and (iv) improvements to LINK’s ATM Replacement Procedure. The PSR is engaging with LINK about the review, and will continue to monitor how LINK meets its commitments. The next SD12 review will be in March 2024.
Speech by Victoria Cleland, Executive Director for Banking, Payments and Innovation
On 20 July, the Bank of England published a speech given by Victoria Cleland, Executive Director for Banking, Payments and Innovation. In the speech, Ms Cleland described the benefits of the project to renew the RTGS and celebrated the migration of CHAPS to ISO 20022 last year. Ms Cleland highlighted the immediate benefits flowing from the transition to ISO 2022, and looked ahead to the second phase of benefits which will flow from the new core settlement engine for RTGS, which will launch in summer 2024. Ms Cleland also spoke about longer-term ambitions including: (i) work to find new ways to connect to RTGS; (ii) a synchronisation interface to connect RTGS with other ledgers; and (iii) extending RTGS operating hours. Ms Cleland also commented that more innovative features will help UK payments be more efficient, and help the UK meet the G20 targets for enhancing cross-border payments.
PRA consults on Pillar 3 remuneration disclosure
On 19 July, the PRA published a consultation paper setting out its proposals to enhance proportionality of Pillar 3 remuneration disclosure requirements, by reducing the number of disclosures required for many smaller banks and building societies. This consultation follows consultations CP4/23 and CP5/23, in which the PRA stated that it would consider the interaction of the disclosure and remuneration proposals, and intended to consult on the new remuneration disclosure requirements in the near future; both of which have been set out in this consultation. The PRA stresses that the proposals in this consultation should not be taken as an indication of its views on the responses to CP4/23 and CP5/23 as it is still considering these. The deadline for comments is 20 September.
Recovery and Resolution
EBA final report on guidelines on overall recovery capacity in recovery planning
On 19 July, EBA published its final Guidelines on the overall recovery capacity (ORC) in recovery planning. The Guidelines establish a consistent framework for the determination of the ORC by institutions in their recovery plans and the respective assessment by competent authorities and aim at strengthening institutions’ effective crisis preparedness. The main goal of the guidelines is to harmonise the observed practices on the ORC determination and assessment, so as to improve the usability of recovery plans and make crisis preparedness more effective. The Guidelines are composed of two sections: (i) section one is addressed to institutions, and aims at providing guidance on the relevant steps to set-up a reliable ORC framework; and (ii) section two is addressed to competent authorities, and complements the framework by harmonising the core elements of the competent authorities’ assessment of the ORC. Moving forward, the Guidelines will be translated into the official EU languages and published on the EBA website. The Guidelines will apply from 3 months after the date of publication of the Guidelines in all EU official languages.
Regulatory Reform Post Brexit
FCA webpage on the repeal and replacement of retained EU law
On 14 July, the FCA published a new webpage on the repeal and replacement of retained EU law (REUL). The Treasury will repeal REUL’s firm-facing requirements and the FCA will replace those provisions, where appropriate, with its own rules. When bringing over the relevant provisions into the FCA Handbook, the FCA will generally do so in line with five core principles, which are in summary: (i) consolidate requirements as far as possible; (ii) use the current Handbook structure; (iii) rely on existing requirements in the Handbook, where relevant and as far as possible; (iv) rely on outcomes rather than prescriptive requirements, where appropriate; and (v) reduce complexity. The webpage includes a table summarising work done so far, key documents and next steps.
EBA consults on draft templates and template guidance to prepare its one-off Fit-for-55 climate risk scenario analysis
On 20 July, the EBA launched a public consultation on draft templates for collecting climate related data from EU banks. The consultation is part of the one-off Fit-for-55 climate risk scenario analysis, which the EBA will carry out with the other ESAs, and with the support of the ECB and the ESRB. The draft templates are accompanied by guidance, which includes definitions and rules for compiling the templates. The draft templates are designed to collect climate-related and financial information on credit risk, market and real estate risks. The collection of counterparty level data will allow the EBA to assess the concentration risk of large climate exposures, as well as to capture amplification mechanisms and assess second round effects. The deadline for comments is 11 October. Following this consultation, the EBA will launch a data collection at the end of November. The one-off Fit-for-55 climate risk scenario analysis is expected to start by the end of 2023, with publication of results envisaged by Q1 2025.
FRC call for evidence on the proposed endorsement of the IFRS Sustainability Disclosure Standards in the UK
On 19 July, the FRC issued a call for evidence on the UK endorsement of IFRS S1 and IFRS S2. Responses will be used to inform the technical assessment of IFRS S1 and IFRS S2 and the aim is to collect views to inform the proposed endorsement of the IFRS Sustainability Disclosure Standards in the UK. In particular, the call for evidence is designed to identify views on whether the disclosures required by the IFRS Sustainability Disclosure Standards, in the context of the UK: (i) will result in disclosures that are understandable, relevant, reliable and comparable for investors; (ii) are technically feasible to prepare; (iii) can be prepared on a timely basis and at the same time as general purpose financial reports; and (iv) are expected to generate benefits that are proportionate to the likely costs. This call for evidence is aimed at those preparing corporate disclosures and for primary users of general purpose financial reports. The deadline for comments is 11 October.
EBA Decision on ad hoc data collection of institutions’ ESG data
On 18 July, the EBA published its Decision on the ad hoc data collection by competent authorities of institutions’ ESG data. In accordance with the Decision, NCAs will gather the relevant ESG data from certain institutions, to allow NCAs and the EBA to fulfil their monitoring functions and ESG-related mandates. This information gathered will derive from the information already disclosed in accordance with institutions’ Pillar 3 obligations in relation to quantitative disclosures on ESG risks. The first annual submission reference date is 31 December, and NCAs will need to submit the relevant data to the EBA by June 2024. The first semi-annual reference date is 30 June 2024, and data will have to be submitted by 31 December 2024. The Decision entered into force immediately.
IOSCO final report on Compliance Carbon Markets
On 17 July, IOSCO published a final report on Compliance Carbon Markets (CCMs), which aims to support IOSCO members seeking to establish new or to enhance their existing CCMs. The report looks at the specific characteristics of CCMs compared to traditional financial markets, and outlines a set of recommendations to making these markets efficient and function with integrity. As CCMs are typically supervised by different types of authorities, the recommendations are addressed to relevant authorities to allow jurisdictions and regulatory authorities the flexibility that may be required.
Joint statement on the EU-US financial regulatory forum
On 20 July, the EU and US regulatory authorities and agencies published a joint statement on the EU-US Financial Regulatory Form which took place on 27 and 28 June. The Forum emphasised close ongoing EU and US cooperation and discussions noted recent international market developments. The Forum focussed on six themes: (i) market developments and financial stability risks; (ii) regulatory developments in banking and insurance; (iii) anti-money laundering and countering the financing of terrorism; (iv) sustainable finance and climate-related financial risks; (v) regulatory and supervisory cooperation in capital markets; and (vi) operational resilience and digital finance. Forum participants will continue to engage on these and other mutually relevant topics ahead of the next Forum meeting.
FCA Annual report and accounts 2022/23
On 20 July, the FCA published its annual report and accounts for 2022/23. In the report the FCA outlines its progress and key achievements in the first year of its strategy, which include: (i) the new consumer duty; (ii) reducing and preventing financial crime; and (iii) supporting firms to launch innovative services. In the past year, the FCA has reduced harm to consumers and businesses by stopping the operations of 627 firms that failed to meet the minimum standards - a 30% increase from the previous year
FCA updates webpage on its perimeter report
On 20 July, the FCA updated its perimeter report webpage, setting out what it does and does not regulate, describing specific issues it sees around the regulatory perimeter, and actions it may take in response to harm or potential harm. The webpage was last updated in March. The revisions to the FCA perimeter reflect recent regulatory developments, namely the FSMA 2023.
Update from the co-chairs on the Regulatory Initiatives Grid
On 17 July, the Financial Services Regulatory Initiatives Forum published an update on the Regulatory Initiatives Grid. Key points from the update include: (i) the regulators are taking steps to operationalise changes to reflect the new obligations and accountability mechanisms introduced by FSMA 2023; (ii) the forum is considering how best to reflect the plan to deliver a smarter regulatory framework, including areas where work has not yet begun; and (iii) following the FCA’s Sustainability Disclosure Requirements and investment labels consultation and the range of comments, the expected policy statement is delayed until Q4 2023. The Grid is expected to be fully updated in Q4 2023, after which the usual publication of biannual updates will resume.
UK signs treaty to join Indo-Pacific trade group
On 16 July, the Department for Business and Trade announced that it has signed the treaty confirming the UK’s accession to the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP). To celebrate the signing, the government released new figures showing CPTPP-owned businesses employed one in 100 UK workers. Being part of CPTPP will mean that more than 99% of current UK goods exports to CPTPP countries will be eligible for zero tariffs. The government will now take the steps needed to bring the agreement into force, expected to be next year.
MPs launch inquiry into barriers faced by women in finance
On 14 July, the Treasury Committee published a call for evidence in relation to an inquiry into the barriers faced by women in financial services. The Committee will examine the progress made in removing gender pay gaps and what role firms, the government and regulators should play in combatting sexual harassment and misogyny. The inquiry will also explore the role of the government and regulators in acting as gender diversity role models, how they should ensure cultures and policies support women’s aspirations and progress, and whether financial services careers should be marketed to a more diverse base of individuals. This inquiry follows the 2018 Treasury Committee inquiry into the same topic, and so will also include an evaluation of the industry’s progress in implementing the 2018 recommendations, as well as the impact of the Treasury’s Women in Finance Charter. The deadline for comments is 1 September.
FCA statement on secondary international competitiveness and growth objective
On 14 July, the FCA published a statement on the secondary international competitiveness and growth objective. The statement introduces the new objective and sets out the FCA’s view of how its work to support the ‘key drivers’ of productivity will support the delivery of the secondary objective. The FCA also explains how it plans to report on its progress in facilitating the new objective in the future, and its approach to updating key processes and documents in light of this change. In particular, the FCA confirms it will be updating the FCA outcomes and metrics framework and notes that it is consulting on the draft rule review framework in accordance with the new FSMA 2023 requirements.
FCA draft rule review framework
On 14 July, the FCA published its draft Rule Review Framework, which it has developed in line with its obligations under FSMA 2023. The FCA explains how it will monitor how the Handbook rules are working in practice. The Rule Review Framework is premised on three types of reviews: (i) an evidence assessment; (ii) a post-implementation review; and (iii) an impact evaluation. The FCA also describes, among other things: (i) what actions it may take where there are barriers to rules working as intended; (ii) the policy-making cycle and rationale for rule reviews; (iii) the FCA’s immediate priorities for review; and (iv) challenges the FCA faces when undertaking reviews. The FCA is inviting comments before it finalises the Rule Review Framework. The deadline for comments is 15 September.