The Wholesale Markets Regulatory Priorities report includes over 50 new and previously announced measures that may affect firms with dealing and investment banking permissions.
By Becky Critchley, Nicola Higgs, Rob Moulton, and Charlotte Collins
When the FCA announced that it would move away from issuing portfolio letters (seemingly to sometimes ill-defined sectors, and at random intervals) with a focused, annual, pre-set list of sectors, this approach received widespread market support. Helpfully, the FCA has now defined the nine sectors that will receive annual updates in its Regulatory Priorities reports, and the cadence at which these documents will appear. Predictability and clarity in regulatory expectations is, of course, generally viewed positively and the FCA is to be supported in this development.
To assist firms, we have analysed the Wholesale Markets paper and identified new announcements, those which were in the Regulatory Initiatives Grid, those that had been announced elsewhere, and those where the timing has changed or firmed up. We also include our estimation of the potential impact of each measure (minor, medium, or major), from the perspective of investment firms with dealing and investment banking permissions. Firms can use this information to identify areas of relevance that we expect to come into the regulatory spotlight.
This report was prepared with the assistance of Henry Smith in the London office of Latham & Watkins.