Luke Rodgers

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On 9 January 2019, the European Central Bank (ECB) has published a consolidated version of its guide to assessments of licence applications. The text, which is not legally binding, combines the content of the first guide published in March 2018 and that of Part 2 (which focuses on capital requirements and programme of operations, including business plans) which follows a public consultation which ended on 25 October 2018. The guide applies to all licence applications…
On 4 January 2019, the FCA published its latest Policy development update. The update contains links to recently issued FCA publications and a table concerning forthcoming FCA publications. Among other things the FCA will publish in January a Policy Statement to Consultation Paper 18/21: General standards and communication rules for the payment services and e-money sectors.…
On 3 January 2019, the Financial Markets Law Committee (FMLC) published a letter to HM Treasury with regards the Financial Services (Implementation of Legislation) Bill (the Bill). The Bill provides HM Treasury the power (in a no deal scenario) to implement and make changes to ‘in flight’ EU legislation, that is instruments that: have been adopted by the EU, but do not yet apply so cannot be captured by the Withdrawal Act (an exhaustive list…
On 27 December 2018, there was published in the Official Journal of the European Union (OJ) Council Decision (EU) 2018/2059 of 29 November 2018 on the position to be adopted, on behalf of the European Union, within the EEA Joint Committee concerning the amendment of Annex IX (Financial Services) to the EEA Agreement. Annex IX of the EEA Agreement is amended by the Council Decision to incorporate into the EEA Agreement: the Fourth Money Laundering…
On 19 December 2018, the FCA published a speech by Christopher Woolard (Executive Director of Strategy and Competition, FCA), Opening up and speaking out: diversity in financial services and the challenge to be met. One of the key messages in the speech is that how a firm approaches diversity and inclusion tells the FCA a lot about its culture. And the way firms handle non-financial misconduct, including allegations of sexual misconduct, is potentially relevant…
On 18 December 2018, the European Banking Authority (EBA) issued a consultation paper on proposed amendments to the European Commission’s Implementing Regulation on the benchmarking of internal models. The proposed amendments seek to adjust the benchmarking portfolios and reporting requirements in view of the benchmarking exercise that will be carried out in 2020. The proposed changes seek to simplify the portfolio’s structure for the credit risk part of the exercise, and gain more insight into…
On 10 December 2018, the Department for Business, Energy & Industrial Strategy (BEIS) published the Government’s response to the consultation of reforms to limited partnership law. The BEIS published a consultation on 30 April 2018 on reforms to limited partnership law. The consultation document set out a range of proposals to achieve this, including stronger controls at the point of registration, requirements for additional information whilst the limited partnership is operating, as well as providing…
On 5 December 2018, the PRA published Policy Statement 30/18: Regulatory Reporting: responses to CP16/18 (PS30/18). In CP16/18, the PRA proposed changes to PRA reporting requirements including: discontinuation of Prudent Valuation Return PV001; changes to PRA reporting instructions to align with updated European Banking Authority (EBA) requirements (RFB001, PRA110, and PRA101 – PRA103); and amendments to ring-fencing reporting requirements (RFB001, RFB003, and RFB004). PS30/18 notes that over the consultation period for CP16/18, the PRA identified…
On 3 December 2018, the Council of the EU published a note (the Note) from its Permanent Representatives Committee (COREPER) regarding the ‘Banking Package’ comprising of legislative amendments to the Capital Requirements Regulation, Capital Requirements Directive IV, the Bank Recovery and Resolution Directive and the Single Resolution Mechanism Regulation. The Note states that the Austrian Presidency has agreed “ad referendum” with the European Parliament to settle a number of outstanding issues on the Banking Package…
On 22 November 2018, the European Payments Council (EPC) published a number of updated versions of its 2017 Single European Payments Area (SEPA) scheme rulebooks, along with new 2019 editions. The updated 2017 Rulebooks become effective on 1 January 2018, the new 2019 Rulebooks become effective on 17 November 2019. Updated 2017 Rulebooks SEPA Credit Transfer Scheme Rulebook; SEPA Instant Credit Transfer (SCT INST) Scheme Rulebook; SEPA Direct Debit Core Scheme Rulebook;…