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02 March 2017

Charles Russell Speechlys host Financial Services Regulatory seminar

Charles Russell Speechlys have hosted another of their regular Financial Services Regulatory update seminars last week, focusing on the challenges the sector is set to face in the coming year.

The seminar attracted an audience from a wide range of financial institutions.

A panel made up of Jonathan Bayliss, Kate Troup and Nick Dashfield discussed topics including:

The introduction of a Product Governance Regime under MiFID II

The Product Governance Regume under MiDIF II has increased obligations on both manufacturers and distributors,  requiring manufacturers  to include a market integrity element to their conflict of interest obligations  and imposing a greater responsibility on distributors to identify the target market and ensuring that products and services they distribute comply with all applicable FCA rules.

The FCA Asset Management Market Study Interim Report

Kate Troup discussed the recent FCA Asset Management Market Study Interim Report, which includes proposals to enhance the duty of asset managers to act in the best interests of investors and raising the possibility of introducing an “all-in  fee”.

FCA and VoP applications under MiFID II

Nick Dashfield spoke of the new Part 4A and VoP application forms, which introduces EU wide informational requirements for the first time, and the new all-encompassing FCA annex. He expressed his views on the new MTF/OTF application requirements and the likely impact of MiFID II on the length of time it will take the FCA to determine Part 4A/VoP applications relating to MiFID II activities and services.

The extension of the Senior Managers and Certification Regime to all financial services firms

The experience of our banking sector clients indicates that the changes required by the regime will take a substantial amount of time to implement, and that firms must take steps in good time to engage with relevant individuals and to prepare compliant materials and procedures.