Imogen Garner (UK)

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Connect: Read more about Imogen Garner (UK)
Firm/Organization: Norton Rose Fulbright
Blogs: Financial services: Regulation tomorrow

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On 17 April 2019, the FCA published the latest issue of Market Watch (no. 59), its newsletter on market conduct and transaction reporting issues. This issue of Market Watch covers: transaction reporting observations from the FCA. The FCA discusses some of the issues its Markets Reporting Team have found regarding the accuracy and completeness of transaction reporting and instrument reference data. The FCA stresses the importance of market participants maintaining adequate procedures, systems and controls…
On 17 April 2019, the Network for Greening the Financial System (NGFS) published its first comprehensive report, A call for action: climate change as a source of financial risk. The NGFS, launched at the Paris One Planet Summit on 12 December 2017, is a group of central banks and supervisors willing, on a voluntary basis, to share best practices and contribute to the development of environment and climate risk management in the financial sector…
On 16 April 2019, the FCA published Primary Market Bulletin No.23. In this Bulletin the FCA finalises its guidance on periodic financial information and inside information, after consulting on updating Technical Note UKLA/TN/506.1 in Primary Market Bulletin No. 19. The FCA also outlines its findings and sets out its expectations on some of the issues raised in its recent supervisory review of the new regulatory requirements for firms managing securities offerings. Introduced in 2018,…
On 15 April 2019, the FCA published Consultation Paper 19/15: Independent Governance Committees: extension of remit (CP19/15). Independent Governance Committees (IGCs) provide independent oversight of the value for money of workplace personal pensions provided by firms such as some self-invested personal pension operators. In CP19/15 the FCA is proposing a new IGC duty to oversee: firms’ environmental, social and governance (ESG) policies. The FCA is also proposing related guidance setting out how providers of pension…
On 15 April 2019, the PRA published Policy Statement 11/19: Enhancing banks’ and insurers’ approaches to managing the financial risks from climate change (PS11/19). PS11/19 is relevant to all UK insurance and reinsurance firms and groups, banks, building societies, and PRA-designated investment firms (collectively referred to as firms). In PS11/19 the PRA provides feedback to responses to Consultation Paper 23/18: Enhancing banks’ and insurers’ approaches to managing the financial risks from climate change (our blog…
The first phase of the Senior Managers’ and Certification Regime (SM&CR) was introduced for about 900 banks and deposit takers in March 2016. On 9 December 2019, the FCA is extending this regime to over 47,000 other firms. The basic principle of the SM&CR is that of responsibility and accountability, it is the antidote to decision-making by default. Firms will need to make changes to their compliance and HR systems and procedures if they are…
On 11 April 2019, the European Securities and Markets Authority (ESMA) published an updated version of its Q&As on the Transparency Directive (TD). The updated Q&As modify question 26 which deals with the situation where the UK leaves the EU without a Withdrawal Agreement and concerns a third country issuer and their disclosure of a new home Member State for the purposes of the TD.…
On 11 April 2019, the European Securities and Markets Authority (ESMA) published an updated version of its Q&As on the Prospectus Regulation. The updated Q&As amend question 103 which has been modified in the event the UK withdraws from the EU without a Withdrawal Agreement and concerns the position where third country issuers have chosen the UK as their Home Member State for prospectus approval. Question 104 is also amended in light of the possibility…
The recording of our latest 40 minute briefing on Brexit and the future of economic partnership for financial services is available for free here. Please note that this recording omits the segment delivered by HM Treasury which was conducted under Chatham House rules.…
On 4 April 2019, the European Securities and Markets Authority (ESMA) issued its first annual report on sanctions imposed by Member State competent authorities (NCAs) under the UCITS Directive. The report provides an aggregated overview of the penalties and measures issued under the UCITS Directive for 2016/2017, based on data submitted to ESMA by NCAs.…