Brexit and financial services—the temporary permissions regime (TPR)
Brexit and financial services—the temporary permissions regime (TPR)

The following Financial Services practice note provides comprehensive and up to date legal information covering:

  • Brexit and financial services—the temporary permissions regime (TPR)
  • Background and legislative framework
  • FCA policy development
  • BoE/PRA policy development
  • Which firms and funds can use the temporary permissions regimes?
  • Firms which can use the regime
  • Firms with MiFID II tied agents
  • Credit institutions and insurers
  • Gibraltar-based firms
  • Other firms which will not be able to use the TPR
  • More...

BREXIT: 11pm (GMT) on 31 December 2020 (‘IP completion day’) marked the end of the Brexit transition/implementation period entered into following the UK’s withdrawal from the EU. Following IP completion day, key transitional arrangements come to an end and significant changes begin to take effect across the UK’s legal regime. This document contains guidance on subjects impacted by these changes. Before continuing your research, see: Brexit and financial services: materials on the post-Brexit UK/EU regulatory regime.

This Practice Note considers the Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA)/Bank of England (BoE) temporary permissions regime (TPR) and temporary marketing permissions regime (TMPR), which will come into force at the end of the implementation period following the UK’s withdrawal from the EU. The TPR and TMPR will allow European Economic Area (EEA) passporting firms and funds to continue to operate in the UK for a limited period of time after the implementation period has ended, to give them time to apply for full UK authorisation or recognition.

The European Union (Withdrawal) Act 2018 (EU(W)A 2018), as amended by the European Union (Withdrawal Agreement) Act 2020 (EU(WA)A 2020), makes provision for the ratification and implementation in domestic law of the Withdrawal Agreement between the UK and the EU. The Withdrawal Agreement sets out the arrangements for the UK’s withdrawal from the EU. It includes a transition period (or, to use

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