Financial

March 27, 2020

On 26 March 2020, the Global Foreign Exchange Committee (GFXC) issued a statement on foreign exchange (FX) market conditions. The statement explains that given the intense volatility seen in global financial markets, FX market participants may execute larger than usual FX volumes during end-of-month benchmark fixings. In addition, FX market participants may face more operational constraints reflecting lockdown in some financial centres. In light of these developments, significant volatility and price movements may be observed…

Financial services: Regulation tomorrow

PRA occasional consultation paper: March 2020

By Joe Bamford (UK)

March 27, 2020

On 26 March 2020, the PRA published Consultation Paper 3/20: Occasional Consultation Paper – March 2020 (CP3/20). In CP3/20 the PRA sets out its proposals to make minor amendments to PRA rules, supervisory statements (SS), national specific templates (NSTs) and associated LOG files, and the market risk sensitivities data item and associated instructions. Specifically CP3/20 covers: Chapter 2: Minor updates and amendments to instructions for completing PRA110; Chapter 3: Non-Solvency II: London interbank offered rate…

Financial services: Regulation tomorrow

FCA announces delay to launch of directory for certified and assessed persons

By Joe Bamford (UK)

March 27, 2020

On 25 March 2020, the FCA updated its web page concerning the Directory of Certified and Assessed Persons. The updated web page states that following the COVID-19 outbreak, the FCA has delayed the publication of the directory of certified and assessed persons, which was due to be published on the FS Register by the end of March, for at least a month. The timing of the launch is now under review and the regulator…

Financial services: Regulation tomorrow

FCA updates payment holiday aspects of guidance for mortgage providers

By Matthew Gregory (UK) & Joe Bamford (UK)

March 27, 2020

On 25 March 2020, the FCA updated its web page providing guidance for mortgage lenders and administrators, and home purchase providers and administrators, on the fair treatment of customers in the light of the COVID-19 pandemic. The section on payment holidays has been updated providing that where a customer is experiencing or reasonably expects to experience payment difficulties as a result of circumstances relating to COVID-19, and wishes to receive a payment holiday, a firm…

Financial services: Regulation tomorrow

Joint statement by FRC, FCA and PRA on corporate reporting

By Simon Lovegrove (UK)

March 27, 2020

On 26 March 2020, the FCA, PRA and Financial Reporting Council (FRC) issued a joint statement in which they announced a series of actions to ensure that information continues to flow to investors and support the continued functioning of the UK’s capital markets. Such actions include: a statement by the FCA allowing listed companies an extra 2 months to publish their audited annual financial reports; guidance from the FRC for companies preparing financial statements in…

Financial services: Regulation tomorrow

FCA outlines financial resilience expectations for FCA solo-regulated firms

By Imogen Garner (UK) & Iona Wright (UK)

March 27, 2020

On 26 March 2020, the FCA issued a short statement outlining its financial resilience expectations for solo-regulated firms. Key points in the statement include: the FCA wants firms to continue operating in this challenging period, and, where it can, it intends to provide flexibility to regulated firms to ensure this; capital and liquidity buffers are there to be used in times of stress. Firms who have been set buffers can use them to support the…

Financial services: Regulation tomorrow

LSB updates Information for Practitioners document relating to Standards of Lending Practice for business customers on product sale

By Joe Bamford (UK)

March 27, 2020

On 26 March 2020, the Lending Standards Board (LSB) published an updated version of its Information for Practitioners document relating to the Standards of Lending Practice for business customers (Standards) on product sale. The LSB has updated paragraph 4 of the document to take account of short-term measures to support lending to small and medium-sized enterprises (SMEs) impacted by COVID-19.…

Financial services: Regulation tomorrow

PRA Dear CEO letter on IFRS 9, capital requirements and loan covenants

By Jochen Vester (UK) & Jonathan Herbst (UK)

March 27, 2020

On 26 March 2020, the PRA published a Dear CEO letter setting out guidance in three areas: consistent and robust IFRS 9 accounting and the regulatory definition of default; the treatment of borrowers who breach covenants due to COVID-19; and the regulatory capital treatment of IFRS 9. The PRA states that all aspects of the Dear CEO letter need the urgent attention of firms. In particular, messages on accounting will be relevant to firms finalising…

Consumer Financial Services Law Monitor

Massachusetts Declares Sweeping Prohibition of Debt Collection Practices in Light of COVID-19

By Christopher Carlson, Ethan G. Ostroff & Ashley L. Taylor, Jr.

March 27, 2020

Today, Massachusetts Attorney General Maura Healey issued a sweeping emergency regulation instituting a prohibition on debt collectors making outbound debt collection calls or pursuing other debt collection practices as a result of the coronavirus (“COVID-19”) health crisis. These rules take effect on March 28, and end when either of the following occurs: (1) 30 days after Massachusetts’s State of Emergency related to COVID-19 is lifted, or (2) June 26, 2020, 90 days after the effective…

FinReg

Fed Updates FAQs for the Money Market Mutual Fund Liquidity Facility

By Randall D. Guynn, Gabriel D. Rosenberg, Christopher M. Paridon & Eric B. Lewin

March 27, 2020

The Federal Reserve has issued updated FAQs regarding its money market mutual fund liquidity facility (MMLF), modifying the FAQs issued on March 21. For more information on the MMLF, please see our memorandum and blog post describing the original MMLF announced on March 18, our blog post describing the expansion of eligible collateral to include municipal bonds on March 20, and our blog post describing the further extension of eligible collateral to include municipal variable…

Financial

GFXC statement on FX market conditions

PRA occasional consultation paper: March 2020

FCA announces delay to launch of directory for certified and assessed persons

FCA updates payment holiday aspects of guidance for mortgage providers

Joint statement by FRC, FCA and PRA on corporate reporting

FCA outlines financial resilience expectations for FCA solo-regulated firms

LSB updates Information for Practitioners document relating to Standards of Lending Practice for business customers on product sale

PRA Dear CEO letter on IFRS 9, capital requirements and loan covenants

Massachusetts Declares Sweeping Prohibition of Debt Collection Practices in Light of COVID-19

Fed Updates FAQs for the Money Market Mutual Fund Liquidity Facility

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