With the Brexit deadline looming in less than two months, Firms should be prepared for the no deal scenario and how this will impact your activities. Breaking news on Friday was ESMA’s announcement that a Memorandum of understanding had been signed allowing delegation of UK Firms to continue for example providing investment management services. This will provide welcome certainty to a number of firms. We explore the various Brexit scenarios in further detail below and would be delighted to share further insights on this or any other regulatory topic.
Post-(no deal) Brexit Temporary Regimes
We update our previous newsletter to note that the FCA is now receiving notifications with regard to the Temporary Permission Regime.
You should familiarise yourself with the TPR requirements NOW if you are an:
If you fall under either of the above categories and wish to continue to passport services into the UK or market your EEA fund into the UK, in the event of a “no deal” Brexit, you must notify the FCA that you wish to enter the “Temporary Permissions Regime”. This will enable you to continue to provide services or market your fund into the UK whilst you apply for full authorisation and lasts up to 3 years from exit day. The FCA is now able to receive TPR notifications (the “notification window” opened on 7thJanuary 2019 and will close at the end of 28thMarch 2019).
For fuller guidance on how to make the notification and the rules that will apply, please consult the FCA TPR
FCA Statement on EU Withdrawal Impact Assessment
This was published 29thNovember and outlined the FCA’s view of the impact analysis of a deal/no deal Brexit (in which the FCA purports to take a neutral stance).
Cyber/Technology Resilience: FCA report (December 2018)
The Report highlights output from 296 self-assessments completed by firms assessing their technology and cyber capabilities. The focus areas were: governance, delivery of change management, managing third party risks, effective cyber defences.
Portman Compliance Consulting LLP specialises in providing pragmatic and commercially-aware regulatory support to small and medium sized FCA regulated firms. Our clients can determine which level of outsourcing they require:
- FCA Authorisation
- Special Projects
We build strong relationships with our clients by understanding their individual business models, risk profiles and by establishing good communication links.
Our objective is to supply comprehensive compliance support to enable our clients to focus on growth and opportunity.
Please get in touch with Nancy King by email firstname.lastname@example.org or phone 0207 205 2249 to find out more information how we can help you in financial compliance. We would be delighted to provide a client CPD at your offices to go through in more detail about this article.