ESMA has issued a stark reminder that reverse solicitation, where it can be used, has to be carefully managed and documented, and is an area of regulatory scrutiny and focus. This short note also takes stock on the EU27...more
FCA Opens Notification Window for Passported EU Firms and Funds under No-Deal Brexit Temporary Permissions Regime - The FCA has announced that the notification window for passported EU ex-UK firms and funds wishing to...more
The House of Commons recently rejected the Withdrawal Agreement. While the UK Parliament is still debating how to leave the EU, a hard Brexit remains an option. To prepare for this possibility, the UK, EU Commission and EU27...more
CFTC - NFA Amends Interpretive Notice Regarding ISSPs - On January 7, the National Futures Association (NFA) issued a notice to its members that amendments to its Interpretative Notice, entitled NFA Compliance Rules...more
BROKER-DEALER - FINRA Seeks Comment on Fintech Innovation in Broker-Dealer Industry - On July 30, the Financial Industry Regulatory Authority (FINRA) issued a Special Notice requesting comment on how to continue to...more
Various industry bodies and regulators, including the Bank of England and Bafin, have recently raised fears that there will be a cliff edge on Brexit for certain types of financial contract, most notably derivatives and...more
One likely impact of the decision of the United Kingdom (UK) to leave the European Union (EU) is that the UK’s financial services industry will lose automatic rights of access to the EU’s free trade area (the Single Market)...more
In Depth - UK Withdrawal Process - The United Kingdom will continue to be an EU member until procedures are completed for exiting the European Union, which is likely to be a long process. Under EU Treaty rules,...more