There might be a deal. There might not be. It might happen at the end of October – or it might not! Either way, the FCA has prepared information to help firms prepare. You can access that information here.
Passporting
The FCA has made transitional arrangements for non-UK firms to continue operating in the UK post-BREXIT. Unfortunately, to date, the EU has not reciprocated and UK firms that wish to do operate in the EU/EEA post-BREXIT will need to contact the relevant regulator in the countries where services are provided to identify what is required to be able to provide those services after BREXIT.
The EU/EEA countries are Austria, Belgium, Bulgaria, Croatia, Cyprus (Republic of), Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden.
Details of all regulators in the EU/EEA can be found here.
A list of dedicated Brexit websites hosted by financial regulators in EEA Member States is available on the FCA website. The FCA has drawn particular attention to the Luxembourg transitional regime for existing contracts where firms must register by 15 September 2019.
The ongoing advice charge conundrum
Paul Jay Compliance 2018, Conduct, FCA, MiFID
A high proportion of advice firms operate a largely recurring income model and with this comes the obligation to conduct client reviews. This is a subject that raises its head frequently with firms, especially with Consumer Duty considerations. Reviews are nothing new but when MiFID II came into effect on 3rd January 2018 it introduced […]