Dear Clients and Friends,
You will recall that our Alert from the summer outlined the changes proposed – and subsequently passed – by the FCA in relation to payment optionality for investment research. At that time, due to legislative technicalities, the proposals only applied to investment firms authorised pursuant to MiFID, notably excluding firms authorised under AIFMD or UCITS legislation.
As foreshadowed at the end of our previous Alert, the FCA has now issued a consultation paper, the intention of which is to broaden the payment optionality for investment research to AIFMs and UCITS management companies.
The Consultation Paper closes for comment on 16th December 2024 and, if the FCA chooses to proceed with introducing these rules to fund managers, they will aim to publish any rules or guidance in a policy statement in the first half of 2025.
