Back to the Future – Part IV – Joint Payments for Research Update
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 […]
Compliance: Delivered – Interim Compliance Officer and resource management solutions
Finding, hiring and on-boarding compliance staff with the right expertise and level of experience is difficult. We know – we’ve hired many compliance professionals ourselves over the past 20 years. Additionally, you may not need, or have budget for, full time and/or permanent hires – you just know you need someone to fill a gap […]
Back to the Future – Part III – Joint Payments (fka Bundled Commissions)
As referenced in our alert from May, the FCA has now released Policy Statement PS24/9 Payment Optionality for Investment Research. The Policy Statement and release of the final rules confirms that asset management firms may buy investment research using joint payments for third-party research and execution services, provided that they meet the new FCA requirements. […]
Criminal Background Checks for Controllers
July 2024 Dear Clients and Friends, Criminal Background Checks on Controllers A brief but potentially important update from the FCA…you may have missed it but in their June quarterly consultation paper the FCA proposed plans to require proposed controllers of regulated firms to complete criminal background checks. If adopted, from January 2025, new controllers, either […]
Year of the Election and Political Donations
June 2024 Dear Clients and Friends, Political Donations – What is the issue? We are all aware that 2024 is the year of the election – globally more voters than ever in history will head to the polls. The UK vote in July, France announced a snap election last week and the US cast their […]
Market Surveillance – Lessons from Failures
May 2024, Dear clients and friends, A recent market watch newsletter (Market Watch 79) saw the FCA return to the topic of market abuse surveillance system and their effective use. What were we reminded of? In brief, a firm must have effective arrangements to detect and report suspicious activity. It is up to each firm […]
Bundled Commissions, FCA Sustainabilty Disclosures and more
Dear clients and friends A mix of news for you in this alert, from bundled commissions to the FCA’s SDR and labelling regime to the proposed updates to the FCA Financial Crime Guide and finally a few statistics from the results of the FCA’s financial resilience survey. Back to the Future – Part II – […]
FCA Alternatives Supervisory Strategy
Dear clients and friends, On 1st March 2024 the FCA published their interim update on its asset management and alternatives supervisory strategy. In this alert we highlight what we believe to be the more applicable and impactful topics for our clients and contacts. Governance The FCA’s first key point is to highlight, not unsurprisingly, that […]
Complying with the Anti-Greenwashing Rule
Complying with the Anti-Greenwashing Rule by May 2024 In late 2023 the FCA confirmed a substantial package of measures to improve the trust and transparency of sustainable investment products and minimise greenwashing. This new regime includes an anti-greenwashing rule (applicable to all FCA Regulated firms), a product labels regime and fund naming requirements (both applicable […]
FCA ESG Regime – a safer environment for investors?
In late November, the FCA confirmed a substantial package – within Policy Statement 23/16 – of measures to improve the trust and transparency of sustainable investment products and minimise greenwashing. The FCA plans to introduce: 1) An anti-greenwashing rule – applicable to all FCA regulated firms; 2) Product labels – applicable to UK funds only; […]