FS weekly highlights—25 April 2019

FS weekly highlights—25 April 2019

In this issue

 

Brexit news
UK regulator updates
European regulator updates
Authorisation, approval and supervision
Prudential requirements
Financial crime
Enforcement and redress
FCA conduct requirements
Markets and trading
Capital Markets Union
Banks and mutuals
Consumer credit, mortgage and home finance
Insurance and pensions
Payment services and systems
FinTech and virtual currencies
Sustainable finance
Islamic finance
Dates for your diary

 

Brexit news

 

Bank of England’s amendments to financial services legislation under the European Union (Withdrawal) Act 2018

The Bank of England (BoE) and the Prudential Regulation Authority (PRA) issued a joint policy statement (PS5/19) which sets out their policy to ensure there is a functioning legal framework when the UK leaves the EU. The policy statement provides feedback and sets BoE/PRA near-final policy following a number of consultations in relation to the UK’s withdrawal from the EU and in particular on amending financial services legislation under the European Union (Withdrawal) Act 2018 (CP25/18), changes to the PRA rulebook (CP26/18 and CP32/18), changes to financial market infrastructure rules and the BoE’s approach to resolution Statements of Policy. Alongside the policy statement the BoE/PRA published a number of EU Exit Instruments which include a number of Binding Technical Standards (BTS) from both the BoE and PRA, Supervisory Statements and a Statement of Policy on the ‘Interpretation of EU Guidelines and Recommendations’ after the UK’s withdrawal from the EU. A full list of the documents published alongside PS5/19 can be found under the ‘Appendices: Section B’ part of the PS5/19 webpage.

FCA publishes an update to its policy paper (PS19/5): Brexit Policy Statement and Transitional Directions

The Financial Conduct Authority (FCA) published updates to PS19/5 which responds to feedback that it received regarding its Brexit consultations, and published near-final rules and a number of BTS instruments. PS19/5 also sets out in more detail how the FCA intends to use the Temporary Transitional Power (TTP). As the FCA notes in the update, it already published the majority of its BTS instruments on 29 March 2019. A small sub-set of FCA BTS instruments were made after 29 March and were published on 18 April 2019, including some where the PRA is the lead authority. The FCA notes in its update that it may publish a further set of TTP directions later in 2019. 

 

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UK regulator updates

 

FCA’s Andrew Bailey on the future of financial regulation

The FCA published a speech by its CEO, Andrew Bailey, on the future of financial conduct regulation. In his speech, delivered at Bloomberg in London, Mr Bailey discussed the theory and practice of regulating ‘in the public interest’, the changing purpose of regulation, and the impact of Brexit. While the FCA can take no position on the substance of Brexit itself, Mr Bailey said the FCA was always of the view that a period of transition is important to avoid the cliff edge risks of a no deal outcome. ‘The extension of Article 50 is welcome in this regard but we will need to continue to prepare for a full range of scenarios’.

FCA publishes Innovation functions: Co-operation agreement with Canadian securities regulators

The FCA published an innovation functions co-operation agreement between itself and a number of Canadian securities regulatory authorities. The co-operation agreement is intended to foster innovation in financial services in the UK and Canadian markets. The agreement establishes a framework for co-operation and referrals between the innovation functions of the FCA and any Canadian authority that is a signatory to the agreement. It follows the conclusion of a similar agreement between the FCA and the Ontario Securities Commission on 22 February 2017, and the subsequent launch of the Canadian securities regulatory sandbox which supports business seeking to offer innovative products, services and applications.

FCA’s April regulation roundup

The FCA published its regulation roundup for April 2019. The roundup focuses on the launch of the FCA’s Business Plan for 2019/20 while hot topics include the FCA’s Mortgages Market Study final report and proposed changes to responsible lending rules, the Investment Platforms Market Study and a Brexit delay update. Among other topics discussed, the FCA notes it will be holding a global anti-money laundering and financial crime TechSprint between 29 July 2019 and 2 August, and also reminds claims management companies that the deadline to apply for authorisation in the first landing slot for authorisation is 31 May 2019. The roundup also includes updates for General Insurers and Life Insurers.

Search for the next governor of the Bank of England begins

HM Treasury and the Chancellor of the Exchequer, Philip Hammond, issued a press release stating that the Treasury started the process of recruiting the next governor of the BoE. The current governor, Mark Carney, took up the role on 1 July 2013 and will step down on 31 January 2020.

 

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European regulator updates

 

ECB’s Benoît Cœuré on the EU economic outlook

The European Central Bank (ECB) published an interview with Benoît Cœuré, a member of its executive board, in which he discusses the euro, interest rates and the EU economic outlook. Mr Cœuré said he hoped the likely rise in anti-EU, anti-euro and populist parties in the forthcoming European elections would not derail the capital markets union (CMU).

MEPs approve provisional investment and access to finance programme

The European Parliament announced that MEPs approved a provisional and partial deal with EU ministers on InvestEU, a new programme to support investment and access to finance during 2021-2027. The programme aims to provide a launchpad for investments which otherwise would be difficult to finance, increase the focus on climate protection and employment, and generate almost €700bn in investments. 

 

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Authorisation, approval and supervision

 

FCA publishes its approach to supervision

The FCA published its ‘Approach to supervision’ document, which sets out the FCA’s role in ensuring fair and honest markets; why and how the FCA prioritises its supervision work; and how, in practice, it supervises the firms and individuals it regulates. The document follows its ‘Our approach to supervision’ consultation paper, which was published in March 2018. The document explains the purpose of, and the FCA’s approach to, supervising firms and individuals and the public value it delivers. The FCA notes that it uses judgement to supervise against a framework of principles and rules that represent minimum standards of conduct. 

 

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Prudential requirements

 

Report on Bank of England's approach to concurrent stress testing

The BoE published a report on its approach to concurrent stress testing, which it asserts shows that concurrent stress testing is delivering value to policymakers, participating firms and the industry more broadly. The report was commissioned in February 2018, by the BoE’s Court of Directors (the BoE’s board) who asked its Independent Evaluation Office (IEO) to conduct an evaluation of the effectiveness of the BoE’s approach to concurrent stress testing. While generally successful and useful, the report also notes that the stress-testing framework is still maturing, and in this context the IEO noted opportunities for refinement.

PRA letter to deposit-takers on written auditor reporting

The PRA’s executive director of prudential policy, Victoria Saporta, wrote to chief financial officers of selected deposit-takers providing formal feedback to firms and auditors on the thematic findings of the PRA’s written auditor reporting work. The letter chiefly concerns firms’ implementation of the expected credit loss (ECL) approach in IFRS 9. Ms Saporta said the PRA recognised that implementing ECL involved significant effort for firms, but that it was starting to deliver credit risk management benefits.

EBA presents overview of draft CRM guidelines at public hearing

The European Banking Authority (EBA) published a presentation, given at a public hearing on 15 April 2019, on its draft guidelines on credit risk mitigation (CRM) for institutions applying the internal rating-based (IRB) approach with own estimates of loss given default. The draft guidelines provide guidance on the application of the CRM provisions currently laid down in the Capital Requirements Regulation (Regulation (EU) 575/2013) (CRR) applicable to institutions using the advanced IRB approach. 

 

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Financial crime

 

Europe’s banks must step up policy on financial crime: S&P

Investors are running out of patience with European banks failing to tackle money laundering allegations head-on, a risky approach that could damage their standing long-term, according to a report published by S&P Global Ratings. The report said that investors, clients and regulators are ‘reducing tolerance’ towards banks making missteps in relation to their anti-money laundering policy as the drip of reports linking European lenders to dirty-money scandals and sanction breaches continues. S&P said there needs to be a ‘step-change in governance and mindset across the industry’ to a bank's approach to financial crime compliance from just box-ticking. 

 

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Enforcement and redress

 

FCA publishes its approach to enforcement

The FCA published its ‘Approach to enforcement’ document, which sets out how the FCA identifies and attempts to drive out behaviour that fails to meet its standards, or is dishonest or unlawful. The document follows the FCA’s March 2018 ‘Our approach to enforcement’ consultation paper. The FCA notes that its overriding principle in its approach to enforcement is substantive justice to ensure that it carries out investigations in a consistent and open-minded way to get the right outcomes. The document outlines its approach to enforcement and how that approach aligns with its Mission.

FCA announce 5% drop in complaints

The FCA issued a press release announcing that during the second half of 2018, complaints decreased by 5%, falling from 4.13m to 3.91m. PPI was the most complained about product, making up 40% of all complaints. This figure, however, represented a decrease of 8% from 1.72m in 2018 H1 to 1.58m in 2018 H2. A change in reporting allowed firms to exclude from their complaints return any PPI complaints where it was established that the complainant did not purchase a PPI policy from the firm.

 

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FCA conduct requirements

 

FCA publishes feedback statement FS19/2 on duty of care

The FCA published a feedback statement (FS19/2) summarising the responses it received to its discussion paper (DP18/5) on ‘a duty of care and potential alternative approaches’, published in July 2018, and setting out next steps. Based on the responses the FCA received to DP18/5 and its early analysis, it identified options for change that are most likely to address potential deficiencies in consumer protection. In FS19/2, the FCA outlines its initial proposals to review its principles of business and consider changes to its regulatory approach to improve consumer protection, which will form an important part of the FCA’s business plan for 2019/2020. Most respondents to DP18/5 considered that levels of harm to consumers were high and there was a need for change to protect them better. 

 

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Markets and trading

 

FCA publishes final report on conflicts of interest and payment for order flow

The FCA published a final report setting out the findings of its payment for order flow (PFOF) multi-firm review. The report, which provides an update to the preliminary findings published in September 2018, focuses on how wholesale broking firms manage conflicts of interest caused when firms continue to charge commission from market makers or liquidity providers for eligible counterparty client business in listed derivatives markets. The FCA advises firms to read the report and consider how to improve their practices, policies, systems and controls to meet their obligations under the recast Markets in Financial Instruments Directive (Directive 2014/65/EU) (MiFID II).

FCA issues Dear CEO letter regarding wholesale market brokerage firms

The FCA issued a Dear CEO letter explaining its position on the key harms that brokerage firms operating in wholesale financial markets pose to their clients and markets. The FCA will focus on what it believes to be the four key drivers of harm in this area over the next two years: (1) compensation arrangements which link broker remuneration to commission (2) poor governance arrangements (3) workflows which do not recognise brokers may perform different regulated activities, and (4) a culture and mindset which underestimates the risk of brokers committing or facilitating market abuse and financial crime through their role as market intermediaries.

ESMA updates list of market makers and authorised primary dealers who are using SSR exemption

The European Securities and Markets Authority (ESMA) published an updated list of market makers and authorised primary dealers who are using the exemption under the Short Selling Regulation (EU) 236/2012 (SSR). ESMA is required under Article 17(13) of the SSR to publish and keep up to date on its website a list of market makers and authorised primary dealers who are using the exemption under the SSR.

CEER note on REMIT and ‘accepted market practices’ in the energy sector

The Council of European Energy Regulators (CEER) published a note on ‘accepted market practice’ in the energy sector, and the framework, definitions and rules under Regulation 1227/2011/EU of the European Parliament and the Council on wholesale energy market integrity and transparency (REMIT).

BoE: financial stability reports do not significantly move financial markets

The BoE published Staff Working Paper No.792 ‘Have FSRs got news for you? Evidence from the impact of Financial Stability Reports on market activity’. The BoE’s working paper investigates the effect that the publication of the BoE’s Financial Stability Reports (FSR) can create on the returns on equity, equity trading volumes, equity bid-ask spreads and credit default swap spreads of UK financial institutions.

 

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Capital Markets Union

 

Commission welcomes progress as European Parliament approves CMU package including reform to covered bonds, SME growth markets, sustainability disclosures and EMIR

At its final plenary meeting of the 2014–2019 session the European Parliament adopted a number of measures in relation to covered bonds, SME growth markets, sustainability disclosures and reform of Regulation (EU) 648/2012 (the European Market Infrastructure Regulation (EMIR)) which are aimed at building a European CMU:

The European Commission welcomed the European Parliament's final votes on legislation putting in place the building blocks of a CMU. In its press release the Commission stated that the adoption of a substantial number of proposals was another building block towards the CMU. As it now stands, 11 out of 13 proposals aimed at building the CMU are agreed upon.

Valdis Dombrovskis on PEPP implementation and the CMU

The European Commission published a keynote speech by its Vice-President for Financial Stability, Financial Services and CMU, Valdis Dombrovskis, on the impact of the pan-European pension product (PEPP) on EU capital markets and sustainable pensions income. Mr Dombrovskis said it was crucial that the new product is implemented correctly, and estimated that, if successful, the European market for personal pension products could triple in size by 2030.

Valdis Dombrovskis on the EU covered bond framework

The European Commission published a keynote speech by its Vice-President for Financial Stability, Financial Services and CMU, Valdis Dombrovskis, on the 2018 proposal for a harmonised EU framework for covered bonds, which was adopted by the European Parliament. Mr Dombrovskis also discussed the progress made by the European Commission in building the CMU and the role of the financial sector in the transition to a climate-neutral economy. Mr Dombrovskis said covered bonds help banks provide large amounts of financing, and demonstrated their reliability and stability during the financial crisis, when other funding sources dried up. Following the European Parliament's vote on the covered bond legislation, the next steps will be adoption by the Council and publication in the EU's Official Journal.

AFME publish article regarding the future of Europe’s capital markets

The Association for Financial Markets in Europe (AFME) published an article by Simon Lewis, its CEO, regarding the future of Europe’s capital markets. The article begins by reminding readers that while the EU’s largest capital market, the UK, is managing Brexit, Brexit itself will likely cause structural disruption to Europe’s capital markets whatever the final outcome. According to Mr Lewis, the European Commission should re-invigorate the CMU project.

 

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Banks and mutuals

 

BoE publishes minutes of the RTGS renewal programme external advisory body

The BoE published the minutes of a meeting of the real-time gross settlement (RTGS) renewal programme external advisory body that was held on 9 April 2019. The RTGS service is the infrastructure that holds accounts for banks, building societies and other institutions. The minutes provide updates to the programme, noting that it is in the ‘design, enable and procure’ phase, and is on track against the published plan. Updates are provided on the two core elements of this phase: Procurement and Transition State One/Enablers.

UNEP FI sets September 2019 launch date for highly anticipated Principles for Responsible Banking

The United Nations Environment Programme Finance Initiative (UNEP FI)–a partnership between United Nations Environment and the global financial sector– set 22 September 2019 as the official launch date of the industry-developed UNEP FI Principles for Responsible Banking. The Principles establish a framework for a sustainable banking system where a bank’s business strategy is aligned with society’s goals, and guide banks in showing how they are making a positive contribution to society. Over 70 banking institutions and over 20 investment and insurance sector institutions already endorsed the Principles ahead of them being available to sign, by submitting a letter of confirmation from their CEO (for banks) or a stakeholder letter (for other endorsing institutions). 

 

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Consumer credit, mortgage and home finance

 

FCA sets out expectations on treating customers fairly

The FCA published a webpage and video on treating customers fairly, and firms’ obligations to put a strategy in place to assess customer needs and fairness throughout the entire customer journey. The video–the first in a series focusing on consumer credit–focuses on six consumer outcomes that firms should strive to achieve to ensure fair treatment of customers. The FCA also published a transcript of the video. Financial promotions, sales and ongoing service are all to be covered in later videos.

FCA releases video on consumer credit product development and marketing

The FCA published a webpage and video on consumer credit product development and marketing, setting out the FCA’s expectations of firms, and what they are required to do under the FCA rules. The FCA says two of the key areas firms may need to consider when thinking about target markets are the vulnerability of customers and the accessibility of their products or services. Alongside the video and general guidance on product development, the webpage contains links to a number of more detailed FCA guides on vulnerable customers, staff remunerations, promotions on social media.

UK Finance publishes monthly mortgage data

UK Finance published its latest monthly data on UK mortgage trends, covering February 2019. Data is shown for first-time buyers and homeowners, house purchase and remortgaging, with affordability measures in the residential and buy-to-let markets. UK Finance says the figures are strong evidence of a mortgage market where customer engagement is high–not just at the outset, but through the life of the mortgage and where lenders provide attractive refinancing options to suit borrower needs. 

 

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Insurance and pensions

 

Pension regulator insists that chair statements include required information

Following the fining of two schemes for failing to include required information in their annual statements, The Pensions Regulator (TPR) warned other schemes that they must produce a chair’s statement that complies with the law. Although the schemes appealed TPR’s decisions to the First-Tier Tribunal, in both cases, the judges decreed that the failure of the trustees to include required information necessitated penalties for non-compliance.

Valdis Dombrovskis on PEPP implementation and the CMU

The European Commission published a keynote speech by its Vice-President for Financial Stability, Financial Services and CMU, Valdis Dombrovskis, on the impact of the PEPP on EU capital markets and sustainable pensions income. Mr Dombrovskis said it was crucial that the new product is implemented correctly, and estimated that, if successful, the European market for personal pension products could triple in size by 2030. 

 

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Payment services and systems

 

EBA Opinion on passport notifications for agents and distributors of e-money

The EBA published an Opinion on the nature of passport notifications of payment institutions (PIs) and electronic money institutions (EMIs) using agents and distributors located in another Member State. The EBA’s Opinion is aimed at assisting national competent authorities (NCAs) understand the criteria they should use for determining when the use of an agent or distributor triggers an ‘establishment' of the appointing institution in the host Member State or falls under the free provision of services. Although the Opinion is addressed to NCAs, given the supervisory expectations it conveys, it is also useful for PIs and EMIs providing services on a cross-border basis within the EU. 

 

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FinTech and virtual currencies

 

Innovate Finance predicts ‘bumper year’ for UK FinTech investment

Innovate Finance released details on FinTech investment in the UK, showing over US$1 billion of investment in Q1 2019. It predicts a ‘bumper year’, but notes that the overall number of deals is actually steadily decreasing, meaning fewer deals but larger deal sizes. Innovate Finance–the independent membership association that represents the UK’s global FinTech community–says Q1 2019 also shows the quickest start to a calendar year of investment in UK FinTech startups, overshadowing the prior four years by a significant margin.

Wife of Bitcoin's 'founder' can sue FX trader in England

The wealthy wife of a bitcoin tycoon can sue a foreign exchange firm for closing her lucrative account in England instead of Cyprus because she qualifies as an ordinary consumer under European Union law, a London court ruled. A High Court judge  ruled that Ramona Ang could proceed with compensation claims accusing Cyprus-based Reliantco Investments Ltd. of terminating her bitcoin futures trading account without allowing her to remove funds. Ang, the wife of self-proclaimed bitcoin creator Craig Wright, invested $200,000 in cash into the bitcoin futures market using Reliancto's forex trading platform, which operates under the name UFX, from January 2017 until the account was terminated in August 2017. She said that the original investment would now be worth $3m if it hadn't been shut down. 

 

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Sustainable finance

 

UNEP FI sets September 2019 launch date for highly anticipated Principles for Responsible Banking

UNEP FI–a partnership between United Nations Environment and the global financial sector– set 22 September 2019 as the official launch date of the industry-developed UNEP FI Principles for Responsible Banking. The Principles establish a framework for a sustainable banking system where a bank’s business strategy is aligned with society’s goals, and guide banks in showing how they are making a positive contribution to society. Over 70 banking institutions and over 20 investment and insurance sector institutions already endorsed the Principles ahead of them being available to sign, by submitting a letter of confirmation from their CEO (for banks) or a stakeholder letter (for other endorsing institutions).

WFE publishes annual sustainability survey for 2018

The World Federation of Exchanges (WFE)–the global industry group for exchanges and CCPs–published the results of its fifth annual sustainability survey, covering the calendar year 2018. The survey is carried out annually to enable the WFE to capture the nature and extent of member engagement with environmental, social and governance (ESG) issues in developed and emerging markets, and to enable the WFE to track the evolution of its members’ engagement with ESG issues.

 

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Islamic finance

 

TheCityUK report claims that Britain is the Western leader for Islamic finance

TheCityUK said it believes the UK to be the leading Western centre for Islamic finance, with Sharia-compliant assets within the UK totalling around US $6bn (£4.7bn) in 2017. This is based on a new report by TheCityUK, supported by international law firm Trowers & Hamlins. The report, entitled, ‘Global Trends in Islamic finance and the UK market’, states that there are more than 15 institutions located in the UK which offer Islamic finance services. That figure is estimated to be almost double the number located in the US, and much more than other Western countries. The UK also boasts five licensed sharia-compliant banks and 72 listed Sukuk on the London Stock Exchange. 

 

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Dates for your diary

 

DateSubjectEvent

 

25 April

 

UK regulator updates

 

The FCA is due to hold its April board meeting on this date.

 

26 April 2019

Financial crime


Anti-money laundering

 

The deadline for responses to FCA CP19/13: Recovering the costs of the Office for Professional Body Anti-Money-laundering Supervision (OPBAS): further consultation on fees structure is 26 April 2019.

 

26 April 2019Financial crime

The deadline for private sector entities and other experts to provide written comments on Paragraph 7(b) of the Financial Action Task Force’s (FATF) Interpretive Note to Recommendation 15 (in relation to clarifying how the FATF standards apply to activities or operations involving virtual assets) is 26 April 2019.

 

26 April 2019

Payment services and systems 


PSR directions

The deadline for responses to the Payment Systems Regulator’s (PSR) consultation on proposed changes to its directions is 26 April 2019.

 

29 April 2019Enforcement and redress

Firms must complete the mailings required by PS19/2: Previously rejected PPI complaints and further mailing requirements – Feedback on CP18/33 and  FCA 2019/7: Dispute Resolution: Complaints (Payment Protection Insurance) (Amendment No 4) Instrument 2019 as soon as reasonably practicable, and at the latest by 29 April 2019.

 

30 April 2019Enforcement and redress

CRL Management must, as per the Financial Services Compensation Scheme’s (FSCS’s) directions, by 30 April 2019 find an alternative insurer to provide replacement cover for Alpha latent defect and structural damage insurance policyholders, whose policies terminated in August 2018.

 

30 April 2019

Banks and mutuals


Recovery and resolution

 

Following the publication of the findings of the independent review of the prudential supervision of The Co-operative Bank Plc, the Treasury Committee announced that it will take evidence from Mark Zelmer, the independent reviewer, on 30 April 2019.

 

30 April 2019Stewardship code

The deadline for responses to the FCAs and the Financial Reporting Council’s (FRC) ‘DP19/1: Building a regulatory framework for effective stewardship’ is 30 April 2019.

 

30 April 2019Insurance

The deadline for responses to FCA ‘CP19/8: General Insurance Value Measures reporting’ is 30 April 2019.

 

30 April 2019Markets and Trading

ESMA’s restriction on the marketing, distribution or sale of contracts for differences (CFDs) to retail clients, in effect since 1 August 2018, will expire on 30 April 2019, unless otherwise extended.

 

30 April 2019

Markets and trading


MiFID II

 

ESMA will publish the annual calculation of the large in scale (LIS) and size specific to the instruments (SSTI) thresholds for bonds (on a per ISIN basis) through the Financial Instruments Transparency System (FITRS) in the XML files and through the Register web interface starting on 30 April 2019.

 

30 April 2019

Insurance


Solvency II

 

The deadline for feedback to European Insurance and Occupational Pensions Authority (EIOPA)’s discussion paper on ‘Systemic risk and macroprudential policy in insurance’ is 30 April 2019.

 

30 April 2019

Markets and trading


Regulation of capital markets

 

From the end of April 2019, a submitter using the existing Electronic Submission System (ESS), will be able request their submission is reviewed under either the current regime or the new Prospectus Regulation.

 

May 2019ESFS

The European Commission’s Omnibus proposal in relation to the European System of Financial Supervision is expected to be adopted at the Economic and Financial Affairs Council (ECOFIN) in May 2019.

 

May 2019Prospectus Regulation

The FCA intends to finalise updates to the Prospectus Rules sourcebook by the end of May 2019 so that issuers who intend to publish a prospectus on or after 21 July 2019 can plan their transactions.

 

1 May 2019Markets and trading

ESMA’s restrictions on the marketing, distribution or sale of contracts for difference to retail clients will be renewed for a further three month period beginning 1 May 2019.

 

1 May 2019

Financial crime


Regulatory fees and levies

 

HMRC will increase its anti-money laundering supervision fees to £300 per premises, and increase the cost of the fit and proper fee to £150 from 1 May 2019. HMRC will also introduce the ‘small business fee’ of £180 for businesses with a turnover less than £5,000 from 1 May 2019.

 

1 May 2019Consumer protection

The deadline for responses to the Department for Business, Energy and Industrial Strategy’s consultation on the requirements imposed by the Consumer Contract Regulations 2013 is 1 May 2019.

 

1 May 2019European regulator updates

Sebastiano Laviola will take up his position as board member, and Director of resolution strategy and co-operation at the Single Resolution Board on 1 May 2019.

 

 

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About the author:
Prior to joining LexisNexis in 2018, Raphael carried out work placements at Willkie, Farr & Gallagher (sat in Debt Finance) and Macfarlanes (sat in Banking and Finance), through which he was able to gain knowledge about a wide variety of financial products and services. Raphael recently graduated in Law from King’s College London where he took a particular interest in modules such as Finance, Credit & Security and Transnational Company Law. Raphael has also worked as a Paralegal at Axiom Stone Solicitors in Mayfair, where he was involved in a wide range of contentious matters.