FCA CP18/36 — The Second Brexit Onshoring Consultation

The FCA has published a second consultation on the Brexit onshoring project. Like the first, and many other Brexit onshoring documents, it is both long and very technical. However, a number of important policy points are made, which are highlighted in this briefing.

Senior Managers Regime -

Under the Temporary Permissions Regime (TPR), the FCA intends to apply the Senior Managers and Certification Regime (SMCR) and the Approved Persons Regime to UK branches of EEA firms in the same way as the regimes currently apply (this contrasts with the PRA’s announcement that it plans to apply the SMCR for third-country branches to both inbound branch and services firms doing business in the UK under the TPR).

Please see full publication below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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