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Key Regulatory Topics: Weekly Update 28 February – 5 March 2020

Allen & Overy publish weekly updates on key regulatory topics affecting the financial services sector. If you would like to receive this update by email and be added to our marketing mailing list please contact 



UK Chancellor outlines UK preparations for assessments of financial services equivalence in letter to EC

On 2 March, HMT published a letter (dated 27 February) from the UK Chancellor of the Exchequer Rishi Sunak, to Valdis Dombovskis, EU Commissioner for Financial Stability, Financial Services and Capital Markets Union, to provide detail on the UK’s preparations for assessments of equivalence. Mr Sunak notes that both parties have agreed to aim for the completion of the equivalence assessments with respect of their respective frameworks by the end of June 2020. He sees no reason why comprehensive findings cannot be delivered by this deadline. To assist, he proposes establishing a dialogue for the exchange of information to support both parties autonomous decision-making on equivalence. Mr Sunak has therefore asked his official to reach out to their EU counterparts and establish a programme of meetings to provide technical information on the UK framework. Mr Sunak reiterates that the UK is committed to working with the EU to build a friendly future relationship on financial services that is based on co-operation between sovereign equals.

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FCA discussion paper on transforming culture in financial services

On 5 March, the FCA published a discussion paper on driving purposeful cultures. In his introduction, Jonathan Davidson, FCA Executive Director of Supervision (Retail and Authorisations) explains that two key features of healthy cultures in firms, that the FCA have noticed, are that they are purposeful and they are safe. Purpose is one of 4 drivers of culture that the FCA supervision team focus and evaluate firms on. It is defined at the FCA as ‘what a firm is trying to achieve’, the firm’s driving force, and the FCA is not attempting to prescribe what this should be, but help firms in realising the benefits of having a purposeful culture. He explains that purpose can be ethical, consumer-driven or people-driven and can be articulated through a number of ways such as a mission, a vision or values. The discussion paper is made up of firm-specific, sector-specific and thematic essays on purposeful culture, to (i) share a range of insights; (ii) highlight the importance of purposeful culture; and (iii) encourage a broader discussion.

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FCA speech on its approach to ensuring firms treat vulnerable customers fairly

On 5 March, the FCA published a speech by Nisha Arora, FCA Director of Consumer and Retail Policy, on its approach to ensuring that firms treat vulnerable customers fairly. Ms Arora’s speech focuses on: (i) outlining the FCA’s forthcoming guidance (consulted on in July 2019), which seeks to give firms greater clarity and explain what, under the Principles for Business, the firms need to do; (ii) the FCA’s aim to see this guidance embedded in firms’ culture, processes and practices and that its supervisors will both be supporting and looking for evidence in firms of this; and (iii) the FCA’s aim to change the discourse from a ‘box ticking’ exercise to a genuine assessment of the needs of vulnerable customers and how firms are responding to this to deliver good outcomes. The FCA will consult on its forthcoming guidance in Spring 2020 with a view to finalising it by the end of the year.

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EBA report on RTS on minimum monetary amount of the PII for mortgage credit intermediaries

On 28 February, the EBA published a report on the review of the RTS specifying the minimum monetary amount of the professional indemnity insurance (PII) or comparable guarantee for mortgage credit intermediaries (EBA/Rep/2020/08). The RTS were published in the OJ in October 2014 as Delegate Regulation (EU) No 1125/2014 specifying the minimum amounts for individual and total claims. This review of the amount was required of the EBA in 2018, although due to the late transposition by some Member States, it was postponed. The report concludes that, based on the assessment, there is currently no evidence that would suggest that the minimum monetary amounts would need to be amended. The EBA stressed that its mandate refers only to the threshold amounts themselves, not to what extent minimum payment amounts are impeded by specific clauses in PII contracts. The RTS on PII will be reviewed every 2 years.

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Financial crime

Please see our Investigations Insights blog on a recent Hong Kong Court of First Instance decision that confirmed the powers of the Securities and Futures Commission to seize smart phones and tablets in the course of executing a search warrant, and to demand passwords. While of no surprise in itself, those subject to investigation now have clear guidance that personal electronic devices are within scope of the SFC’s powers, and full access must be given to the SFC upon demand

FMLC: Response to the European Commission AML Roadmap

On 3 March, the FMLC published responding to the Commission’s roadmap which identifies the areas where further action is needed at the EU level in order to achieve a comprehensive and effective AML framework. The response focuses on the importance of legal entity identifiers in combating money laundering and the scope of MLD5 in the context of virtual currencies and related activities.

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Money Laundering and Terrorist Financing (Amendment) Regulations 2019

On 28 February, the Parliamentary Joint Committee on statutory instruments published a report highlighting some defective drafting in relation to the Money Laundering and Terrorist Financing (Amendment) Regulations (the Regulations). The Committee had drawn the special attention of both Houses to these Regulations (which implement MLD5) on the ground that they are defectively drafted in one respect. Regulation 8 (inserted new regulation 74C(1)) allows the FCA to impose a direction on a cryptoasset business. The Committee asked HM Treasury to explain why the provisions in regulation 74C(9) to (16) and (20) do not apply to a direction imposed under regulation 74C(1). In a memorandum printed at Appendix 12, HMT explains that paragraph (5) (imposition of a direction on the FCA’s own initiative) and (6) (imposition of a direction by the FCA on the request of the cryptoasset business) of new regulation 74C are not intended to be distinct from the power referred to in paragraph (1) but rather to particularise the manner in which such a direction may be imposed. Where the FCA imposes a direction on its own initiative paragraphs (9) to (16) and (20) will apply and where the FCA imposes a direction on the request of a cryptoasset business paragraphs (17) to (20) will apply. HMT has accepted that regulation 74C could have been clearer and undertakes to amend the instrument at the earliest opportunity.

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FCA publishes the number of STORs received in 2019

On 28 February, the FCA published their suspicious transaction and order reports (STORs) figures for the year ending December 2019. The STOR regime requires market participants to identify and report suspicions of potential market abuse to the FCA. Since 2016, the FCA has seen an annual increase in the number of STORs from market participants, however figures for 2019 show the first decrease in the total number of reports. There may be several reasons for the decrease, including the fact that the FCA has observed some firms taking more robust steps to tackle financial crime risks following the publication of chapter 8 of the Financial Crime Guide. The 2019 figures also show the number of commodity and fixed income STORs have continued to rise which, the FCA believes, reflects steps taken by firms to improve their detection capabilities. The FCA has also seen an increase in the number of market observations received. It launched the Market Observation form in 2019, having recognised that firms often want to submit information about market activity they have observed which is not necessarily appropriate as a STOR.

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FCA report on the evolution of its TechSprint Approach

On 3 March, the FCA published a report on the evolution of its TechSprint model, sharing its insights and best practices as well as evaluating the model, noting areas where the FCA is working to develop its approach. The FCA has held 7 TechSprints since their inception in April 2016. Key outcomes include: (i) profound and rapid learning for regulators and firms; (ii) signalling regulatory interest in an issue and increasing market focus; (iii) forging new partnerships and networks; and (iv) speeding up the development of prototype solutions. The FCA notes however that the true value of TechSprints is difficult to quantify and that maximising post-sprint momentum and progress continues to present challenges with both regulators and the teams involved facing challenges including: (a) securing partnership with a financial institution; (b) maintaining the team dynamic; (c) a lack of regulatory clarity; and (d) a lack of data assets and other resources. Nevertheless, when the key components are executed well, great outcomes are delivered and the FCA will continue to work towards providing ongoing support and tools to allow TechSprint solutions to move from ideas to production.

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EBA Chair’s speech on digital finance priorities for 2020

On 3 March, the EBA published a speech by José Manuel Campa, EBA Chair, in which, among other things, he sets out the EBA's priorities for 2020 relating to digital finance. He notes the progress it has made towards removing obstacles to the application of innovative technologies in the banking and payment sectors, by committing to technological neutrality in its regulatory and supervisory approach. FinTech remains a strategic priority for the EBA and it will continue its work on emerging technologies including: cryptoassets, artificial intelligence, Big Data, machine learning, and wider innovation monitoring. The EBA will focus its attention in: (i) RegTech, stepping up monitoring of RegTech solutions that enable market participants to address their regulatory and compliance requirements more efficiently, identifying any potential obstacles for the use of RegTech; (ii) SupTech, enhancing the sharing of use cases between competent authorities across the EU to facilitate a common approach to the use of technologies; (iii) platformisation, undertaking a new thematic piece of work focusing on some of the structural changes the EBA is observing in the financial sector, specifically the trend towards the reaggregation of products and services on platforms, and emerging new forms of interconnection; and (iv) operational resilience, supporting the consistent implementation of the guidelines on information and communication technology (ICT) risk and security management.

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ESMA Speech: Innovation on a Grand Scale

On 3 March, Steven Maijoor gave a speech at the Afore Consulting 4th Annual FinTech and Regulation Conference in Brussels focusing on the growing scale of financial technology and the firms involved, and what this means for financial services regulation. The ESMA Chair outlined the trends ESMA are seeing in relation to BigTech in finance before considering DLT and the possibility of global stablecoins being an area where BigTech and DLT may intersect.

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Fund regulations

FCA Policy Statement on changes to permitted link rules to facilitate investment in patient capital

On 4 March, the FCA published policy statement (PS20/4), on changes to the permitted links rules in COBS that seek to address any unjustified barriers tor retail investors investing in a broader range of patient capital in unit-linked funds, while maintaining an appropriate degree of investor protection. Patient capital can include venture capital, private equity, private debt, real estate and infrastructure - illiquid investments intended to deliver long-term returns. The FCA received broad stakeholder support for its proposals and in most areas will implement them as proposed. However in relation to: (i) the rules relating to investment in permitted land and property; and (ii) the level of the overall threshold limit on illiquid assets held as permitted links - the FCA has revised its proposals. The final measures remove some of the restrictions on the type of illiquid assets in which investment may be made, whilst setting an overall limit of 35% on the proportion of the fund that may be invested in these assets. Investments in land and property will not be included in this 35% with the existing limits continuing to apply. Use of these extended permissions is conditional on the insurer: (a) continuously ensuring that the investment are suitable and that the timing of benefits due to a policyholder are not negatively affected by liquidity issues; and (b) clearly setting out the risks and consequences to a policyholder. The changes come into effect immediately.

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ESMA’s official translations for guidelines on MMF stress scenarios

On 3 March, ESMA published the official translation of its guidelines on stress test scenarios produced under Article 28 of the Regulation on money market funds (MMFs), applying to national competent authorities (NCAs), MMFs and managers of MMFs. NCAs to which these Guidelines apply must notify ESMA whether they comply or intend to comply with the Guidelines, within two months of the date of publication of the official translations. The Guidelines establish common reference parameters for the stress test scenarios to be included in the stress tests conducted by MMFs or managers of MMFs in accordance with the Article 28 of the MMF Regulation. Their main purpose is to ensure, common, uniform and consistent application of this article’s provisions.

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FCA Feedback Statement on patient capital and authorised funds

On 28 February, the FCA published a feedback statement (FS20/2) in response to its December 2018 Discussion paper (DP18/10) on whether there are any unnecessary barriers to investing in patient capital through authorised funds. The FCA found no inappropriate barriers to investing in patient capital within its authorised funds regime. Broadly, respondents found the current regime fit for purpose for long-term investments by professional and sophisticated retail investors. Specifically, respondents agreed that UCITS and non-UCITS retail schemes only provide limited options relating to long-term assets because of restrictions intended to offer a degree of protection to retail investors. However, qualified investor schemes (QIS) are suitable for investment in long-term assets. Regulatory barriers identified by respondents included: (i) dealing frequencies; (ii) the pension charge cap; and (iii) a reluctance from distributors to accommodate funds that do not offer daily dealing and tax rules. The FCA, acknowledging the barriers that limit the range of available investment options, explains that it is not clear how these are inappropriate or how they may be relaxed without introducing an inappropriate amount of risk to retail investors. There are alternative ways for retail investors to access patient capital such as investment trusts. Other issues addressed in the response include: (a) diversification rules in authorised funds can be problematic and inflexible for fund managers investing in these types of assets; (b) there is a limited use of European long-term investment funds due to the complex operational and demanding suitability requirements. In the final chapter, the FCA provide an overview of the Investment Associations’ long term asset fund proposal and outlines its initial response in terms of ensuring adequate levels of investor protection. The FCA is working with the FPC currently in this area and the FCA will consider any rule changes that may be recommended upon completion of the FPC work later this year.

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Markets and market infrastructure

ESMA’s terms of reference for the CCP Supervisory Committee

On 3 March, ESMA published the terms of reference (dated 13 November 2019) for the central counterparty (CCP) supervisory committee (CCPSC), which Article 41 EMIR requires ESMA to establish as a permanent internal committee. The terms of reference specify the responsibilities and functioning of this committee, its composition and decision-making procedures. The terms will be reviewed every two years.

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ESMA report on C6 energy derivative contracts and the EMIR requirements

On 2 March, ESMA published a report (dated 29 January) on C6 energy derivative contracts and related obligations under EMIR as an input to the EC’s own report on the same topic, which is mandated under the MiFID II Review. The report focuses on the adequacy of the current temporary exemptions that c6 energy derivative contracts benefit from in relation to: (i) the clearing obligation; (ii) the exchange of collateral; and (iii) the inclusion of such contracts in the calculation for the purpose of determining counterparties’ positions against the clearing thresholds. The report assesses the potential benefits in terms of reducing counterparty and systemic risks by making these contacts subject to the EMIR requirements, concluding that there is no urgency to change the regulatory regime and the changes are not expected to have an immediate major impact so the benefits are questionable. This market is much smaller in relative terms compared to the rest of the derivatives market. ESMA also notes that the withdrawal of the UK from the EU creates some uncertainty, with an important share of C6 energy derivatives contracts being either traded or cleared in the UK. Consequently, it concludes that it would be more prudent to wait before considering a change to the regime.

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ESMA's annual transparency calculations for equity and equity-like instruments results

On 28 February, ESMA announced that it has made available the results of the annual transparency calculations for equity and equity-like instruments. The calculations include the determination of: (i) the liquidity assessment as per Articles 1 to 5 of CDR; (ii) of the most relevant market in terms of liquidity as per Article 4 of CDR (RTS 1); (iii) of the average daily turnover relevant for the determination of the pre-trade and post-trade large in scale thresholds; (iv) of the average value of the transactions and the related the standard market size; and (v) of the average daily number of transactions on the most relevant market in terms of liquidity relevant for the determination of the tick-size regime. Currently, there are 1,493 liquid shares, and 788 liquid equity-like instruments other than shares, subject to calculations relating to the transparency requirements in MiFID II and MiFIR. ESMA's annual transparency calculations are based on the data provided to the ESMA financial instruments transparency system by trading venues and arranged publication arrangements relating to the 2019 calendar year.

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ESMA: Updated CSDR Q&As

On 28 February, ESMA published an update to the list of questions under development. Five new questions were added to the post trade section querying the application of the CSDR RTS on Settlement Discipline in certain prescribed circumstances.

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Payment services and Payment systems

PSR issues new directions and response to consultation feedback

On 5 March, the PSR published the new versions of: (i) Specific Direction 1: Access (sponsor banks); (ii) General Direction 1: Co-operative relationships with the PSR; (iii) General Direction 2: Access (FSBRA); (iv) General Direction 3: Access (PSRs 2017); (v) General Direction 4: Service-user interests (interbank payment systems); and (vi) General Direction 5: Conflict of interest (FSBRA).The PSR has published an explanation of its review of its existing directions in a paper. It has issued new general directions 1 to 5, which will take effect from 5 April. It has also consolidated general direction 4 and 6 into a single general direction 4, which will take effect from the same date. The new specific direction (SD1) will take effect from 5 May, the slightly longer transition period is to allow time for sponsor banks to change their processes and procedures to ensure they are compliant with the new timeline obligation

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EPC updates 2019 SEPA scheme rulebooks

On 5 March, the European Payments Council (EPC) announced the publication of a number of updated versions of its 2019 Single European Payments Area (SEPA) scheme rulebooks: (i) Credit Transfer Scheme rulebook; (ii) Instant Credit Transfer rulebook; (iii) Direct Debit Core Scheme rulebook; (iv) SDD Business-to-Business Rulebook; and (v) Proxy Lookup Scheme rulebook. The EPC has also published an updated version of the document ‘Maximum amount for instructions under the SCT Inst Scheme rulebook’, which sets out the maximum amount per instruction that can be processed under the SCT Inst scheme. The updated versions of the 2019 SEPA scheme rulebooks include an updated version of the SEPA Payment Scheme Management Rules, reflecting the creation of a Dispute Resolution Committee (DRC), which will be responsible for complaints management and appeals for all EPC-managed payment and payment-related schemes. The updated versions of the rulebooks are in force from 1 April to 21 November 2021, except for the Proxy Lookup Scheme rulebook, which will come into effect on 1 June.

Credit Transfer Scheme rulebook

Instant Credit Transfer rulebook

Direct Debit Core Scheme rulebook

SDD Business-to-Business rulebook

Proxy Lookup Scheme rulebook

Maximum amount for instructions under the SCT Scheme Rulebook

FCA Webpage: Using payment service providers

On 28 February, the FCA published a new webpage which recognises that there are many ways to make payments and highlights the different types of non-bank payment providers. The pages explore that different types of protections that are available to consumers depending on the type of firm they are using.

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Prudential regulations

EBA submits additional analysis on final Basel III reforms on output floor and equity exposure class

On 5 March, the EBA published a letter to John Berrigan, Director General for Financial Stability, Financial Services and Capital Markets Union at the EC, responding to the EC’s July 2019 request for additional analysis for its call for advice on Basel III reforms. The EBA set out the scope of the data collection used in the analysis, clarifying which entities were included, cautioning on the interpretation of the results as simplifying assumptions were likely used by banking groups, given the complexity of the exercise. The analysis is based on a sample of 221 institutions belonging to 51 banking groups It concludes, inter alia, that: (i) the overall impact of applying the output floor at the individual level does not seem to be particularly high, except for co-operative banks; and (ii) the impact of the implementation of the Basel III framework to equity exposures at the individual and sub-consolidated level has a significantly higher impact than at consolidated level and it is mainly driven by intra-group equity exposures.

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PRA ‘Dear Chair’ letter on its board diversity rules

On 4 March, the PRA published a letter to chairs of regulated firms aiming to reinforce the importance it places on diversity for improving decision-making and providing effective challenge. The PRA seeks to remind firms of the requirement to comply with PRA rules in this area. As noted in supervisory statement SS5/16 on corporate governance, the PRA has set out its expectation on boards to have the diversity of experience and capacity to provide effective challenge across the full range of its business, with particular importance as a firm’s business changes and the external context evolves. In line with this, the PRA requires firms to have a board diversity policy in place. The PRA refers to the EBA’s report on the benchmarking of diversity practices in February that showed that compliance is not yet universal among UK credit institutions with 70% of those sampled having a policy in place. The PRA continues to remind different firms such as insurers and significant credit institutions and investment firms of their respective requirements. The PRA invites Chairs, amongst other things, to take remedial action where necessary, considering to what extent the diversity policy is embedded in recruitment and succession planning for the board. Chairs should expect to discuss this with their supervisors through the course of their normal supervisory dialogue.

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PRA policy statement on its approach to supervising liquidity and funding risks

On 2 March, the PRA published a policy statement (PS4/20) and updated its supervisory statement on its approach to supervising liquidity and funding risks (SS24/15). The Policy Statement provides feedback to responses to the proposals in Consultation Paper (CP) 27/19. The changes were necessary in order to reflect the BoE’s October 2019 Market Operations Guide outlining the framework in operations in sterling money markets. Respondents generally welcomed the proposals, but did request some clarifications and suggested limited changes. The PRA, having considered the responses, has made no changes to the proposals outlined in CP27/19. It will align supervisory practice with the new policies outlined in SS24/15 and the Market Operations Guide. The updated policy comes into effect immediately.

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EBA submits additional analysis on Basel III reforms on specialised lending and MREL in letter to EC

On 2 March, the EBA published a letter (dated 25 February) to John Berrigan, Director General for Financial Stability, Financial Services and Capital Markets Union at the EC, about additional analysis for the Commission's call for advice on Basel III reforms. In July 2019, the EC requested additional information from the EBA in the areas of specialised lending, minimum requirement for own funds and eligible liabilities (MREL), intra-group equity exposures and the application of the output floor at all levels. Annex 1 contains the EBA's analysis on specialised lending, setting out an overview of the use of regulatory approaches and portfolio composition. Annex 2 discusses the impact of Basel III on MREL.

EBA letter

Annex 1

Annex 2

EBA report on assessment of institutions’ Pillar 3 disclosures

On 2 March, the EBA published a report assessing the Pillar 3 disclosures made by 12 systemically important credit institutions based on an end-2018 disclosure reference date, aiming to identify best practices and areas for improvement. The report is based on standards included in EBA guidelines on disclosure requirements under CRR and the liquidity coverage ratio disclosure guidelines. The EBA observes that institutions are on the correct path towards achieving consistency and comparability through the implementation of common disclosure formats, accompanied by qualitative explanations that help communicate meaningful prudential information. Areas for improvement include: (i) omissions and incomplete disclosures without explanations; (ii) unclear identification and location of Pillar 3 reports, making them difficult to be accessed; (iii) lack of consistency in the structure of reports; (iv) oversimplification of interim reports; and (v) lack of reconciliation of quantitative information across disclosure templates or inconsistent ways to calculate quantitative flows of information. The EBA also observes that ESG related information is still scarce and diffuse, however institutions are starting to embed sustainability considerations in their strategic agenda and to recognise environmental and climate change risks as emerging risks. The EBA has also published a timeline showing how and when it is implementing its Pillar 3 strategy.

EBA report

EBA timeline

PRA consultation on reconciling capital requirements and macroprudential buffers

On 28 February, the PRA began consulting on updating the Pillar 2A capital framework, following the FPC decision to raise of the UK CCyB rate from in the region of 1 to 2% (to take affect in December 2020). The PRA proposes to reduce variable Pillar 2A capital requirements to take account of the additional resilience associated with higher macroprudential buffer requirements in a standard risk environment. The proposals in the paper clarify the considerations that the PRA takes into account when it carries out an overall assessment of the level of capital that would be sufficient to ensure the sound management and coverage of firms’ risks. A draft of the proposed amendments to: (i) supervisory statement ‘The Internal Capital Adequacy Assessment Process’; and (ii) ‘The Supervisory Review and Evaluation Process’, are included in the appendix. The paper forms part of a package including the FPC review of capital requirements and the BoE’s clarification on converting debt to CET1 capital. The proposed implementation date is 6 July, with the Pillar 2A reduction being applied at the same time or before the 2% rate comes into effect in December. The deadline for comments is 30 April.

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Other developments

Seven EEA Joint Committee Decisions amending Annex IX (Financial Services) to EEA Agreement published in OJ

On 5 March, seven Decisions of the EEA Joint Committee that amend Annex IX (Financial Services) to the EEA Agreement were published in the OJ. Among other things, the Decisions incorporate into the EEA Agreement the Insolvency Hierarchy Directive and various pieces of EU financial services legislation relating to the Insurance Distribution Directive, MAR, UCITS, CSDR and the Credit Rating Agencies Regulation.

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FCA and BoE statements on Covid-19

On 4 March, the FCA published a statement on its expectation for firms and their contingency plans to deal with major events such as the Covid-19 outbreak. The FCA is working alongside the BoE and HMT in actively reviewing contingency plans for a wide range of firms, including (i) an assessment of operational risks; (ii) the ability of firms to continue to operate effectively; and (iii) the steps firms are taking to serve and support customer. The FCA expects firms to be able to (a) continue to enter orders and transactions promptly into the relevant systems; (b) use recorded lines when trading; and (c) give staff access to the compliance support they need. If firms are able to meet these standards and undertake these activities from backup sites or with staff working from home, we have no objection to this. The FCA will keep its guidance under review. In conjunction, the BoE published a Governor statement on 3 March. The statement confirms that the BoE is monitoring the situation closely with: (1) the FPC examining macro-financial impacts such as spill-overs to market functioning and how to address any possible constraints on financing to UK businesses and households; and (2) the PRC (PRA) reviewing the contingency plans of banks, insurers and financial market infrastructure.

FCA statement

BoE statement

FCA Handbook Notice 74

On 28 February, the FCA published Handbook Notice 74, which sets out changes to the FCA Handbook made by the FCA board on 30 January and 27 February. The Handbook Notice reflects changes made by the following instruments: (i) Pension Schemes (Disclosure of Transaction Costs and Administration Charges) (Amendment) Instrument 2020; (ii) Insurance: Conduct of Business Sourcebook (Access to Travel Insurance) Instrument 2020; and (iii) Fees (Miscellaneous amendments) (No 15) Instrument 2020. The Handbook Notice also contains the response to the November 2019 consultation on the changes contained within the Notice.

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