1. finance
2. bank

26 MARCH 2015
ISSUE 804
Financial Regulation
Weekly Bulletin
Major UK and European regulatory developments of interest to banks, insurers and reinsurers,
asset managers and other market participants
QUICK LINKS:
Selected Headlines
Selected Headlines
General
Banking and Finance
Insurance
Asset Management
Securities and Markets
Financial Crime
Enforcement
GENERAL
PRA Policy Statement PS3/15: Strengthening individual accountability in
banking and insurance - Responses to CP14/14 and CP26/14
Business Plan 2015/16 - published by FCA and includes Risk Outlook
If you have any comments
or questions, contact
Elizabeth Prentice.
Slaughter and May also
produces a periodical
Insurance Newsletter. If
you would like to go on
the distribution list, please
contact Beth Dobson.
BANKING AND FINANCE
CRR - Commission Delegated Regulation amending Delegated Regulation
on own funds requirements published in Official Journal
Transposition of the Bank Recovery and Resolution Directive - HM
Treasury publishes response to consultation
Restricting tax relief for banks’ compensation expenditure - HM Treasury
publishes consultation paper
Ex-post risk adjustment to variable remuneration - FCA publishes
guidance consultation paper GC15/02
The Bank of England Act 1998 (Macro-prudential Measures) Order 2015
The Bank of England Act 1998 (Macro-prudential Measures)(No.2) Order
2015
The Mortgage Credit Directive Order 2015
A new regulatory framework for payment systems in the UK - PSR
publishes policy statement PS15/1
4.1
5.1
9.1
12.1
12.2
14.1
15.2
15.3
15.4
16.1
INSURANCE
Solvency II - Six Commission Implementing Regulations on ITS published in 18.1 to 18.6
the OJ
Solvency II: a new regime for insurers - PRA publishes Policy Statement
20.1
PS2/15
Solvency II - supervisory approval for the volatility adjustment - PRA
20.2
publishes consultation paper CP11/15
Solvency II - PRA publishes webpages on approvals and waivers
20.3
General Insurance Add-ons Market Study - FCA publishes consultation
21.3
paper CP15/13 - Proposed Remedies: Banning opt-out selling across financial
services and supporting informed decision-making for add-on buyers
FINANCIAL REGULATION
26 March 2015
QUICK LINKS:
Selected Headlines
Asset Management
General
Securities and Markets
Banking and Finance
Financial Crime
ASSET MANAGEMENT
Conflicts of interest - HFSB consults
The Financial Conduct Authority v Capital Alternatives Limited [2015]
EWCA Civ 284
SECURITIES AND MARKETS
Code of Conduct Fundamentals for Credit Rating Agencies - IOSCO
publishes final form
MiFID II - ESMA consults on draft guidelines for complex debt instruments
and structured deposits
CRA Regulation - ESMA issues call for evidence on disclosure requirements
for structured finance instruments
Developing our approach to implementing MiFID II conduct of business
and organisational requirements - FCA publishes Discussion Paper DP15/3
MiFID II - ACER publishes recommendation to the European Commission
FINANCIAL CRIME
The Serious Crime Act 2015 (Commencement No. 1) Regulations 2015
ENFORCEMENT
Insider dealing - Former trader sentenced to 19 months imprisonment and
fined £100,000
Insurance
Enforcement
25.1
26.1
27.1
29.1
29.2
32.1
33.1
35.1
36.1
General
1.
European Systemic Risk Board
1.1
Risk Dashboard - published by ESRB - March 2015 - The European Systemic Risk Board has published its
latest risk dashboard containing a set of quantitative indicators relating to systemic risk.
The Risk Dashboard is here.
The overview note is here.
2.
HM Treasury, Financial Conduct Authority and Money Advice Service
2.1
Money Advice Service - HM Treasury publishes independent review and government, MAS and the
FCA publish responses - March 2015 - HM Treasury has published the results of an independent review
of the Money Advice Service (MAS) conducted by Christine Farnish. In the review, Ms Farnish makes 25
recommendations (Appendix A). The HM Treasury, MAS and the FCA have all published responses. MAS and
the FCA are to publish evidence and action plans and submit them to the government in the autumn. The
government is to publish its conclusions before the end of the year.
The independent review document is here.
The holding page is here.
HM Treasury’s response is here.
02
QUICK LINKS:
Selected Headlines
Asset Management
General
Securities and Markets
Banking and Finance
Financial Crime
FINANCIAL REGULATION
26 March 2015
Insurance
Enforcement
The press release is here.
The response by the MAS is here.
The press release is here.
The response by the FCA is here.
The press release is here.
3.
Bank of England and the Financial Conduct Authority
3.1
Memorandum of Understanding between the FCA and the Bank of England, including the PRA, and
with the PSR - March 2015 - A Memorandum of Understanding (MoU) between the FCA and the Bank,
including the PRA, dated March 2015, has been published.
HM Treasury has also published an MoU setting out the high-level framework used by the Bank, FCA, PRA
and Payment Systems Regulator (PSR) to cooperate with one another in relation to payment systems in the
UK.
The MoU is here.
The PSR MoU is here.
4.
Prudential Regulation Authority
4.1
PRA Policy Statement PS3/15: Strengthening individual accountability in banking and insurance Responses to CP14/14 and CP26/14 - March 2015 - The PRA has published a policy statement (PS3/15)
which contains the first set of near final rules implementing (i) the Senior Managers and Certification
Regimes for UK banks, building societies, credit unions and PRA-designated investment firms, and (ii) the
Senior Insurance Managers Regime (SIMR) for Solvency II insurance firms. The rules for both regimes come
into force on 7 March 2016, with certain aspects of the Senior Insurance Managers Regime applying from
1 January 2016.
The PRA expects to issue a second set of rules applying to outstanding aspects later in the year. These
include:
•
conduct rules;
•
transitional and operational arrangements;
•
consequential amendments;
•
the treatment of non-executive directors (NEDs);
•
the approach to the presumption of responsibility in section 66B of the Financial Services and Markets
Act 2000 (FSMA); and
•
the application of the new regimes to UK branches of foreign banks.
03
QUICK LINKS:
Selected Headlines
Asset Management
General
Securities and Markets
Banking and Finance
Financial Crime
FINANCIAL REGULATION
26 March 2015
Insurance
Enforcement
The PRA envisages some amendments may be made to the near final rules published in PS3/15 in order to
incorporate outstanding elements and align terminology and cross-references.
PS3/15 includes feedback on certain elements of CP14/14 (‘Strengthening accountability in banking: a new
regulatory framework for individuals’), and CP26/14 (‘Senior insurance managers regime: a new regulatory
framework for individuals’). The FCA published its feedback on CP14/14 in CP15/9 (in ‘Strengthening
accountability in banking: a new regulatory framework for individuals’); reported in this Bulletin last week.
To coincide with the release of PS3/15, the PRA has launched a new webpage on ‘strengthening
accountability’. Among other things, it announces that the PRA will launch a consultation to cover technical
issues for the SIMR, including new forms and transitional arrangements and a consultation for a streamlined
SIMR for smaller insurers that shall fall outside the scope of Solvency II on 27 March 2015.
PS3/15 is here.
CP14/14 is here.
CP26/14 is here.
The policy statement webpage is here.
The press release is here.
The new webpage is here.
5.
Financial Conduct Authority
5.1
Business Plan 2015/16 - published by FCA and includes Risk Outlook - 24 March 2015 - The FCA has
published its Business Plan for 2015/2016 setting out key areas of focus for the following year. This year
it includes the FCA’s Risk Outlook. Annex 1 of the Business Plan contains a chart of current and planned
market studies and thematic work; Annex 2 contains current EU initiatives; and Annex 3 contains an FCA
organisation chart. In addition, following the announcement of its new strategic approach in December
2014, the FCA has created two new divisions: the ‘Supervision Investment, Wholesale and Specialists’
Division, which will be led by Tracey McDermott; and the ‘Retail and Authorisations’ Division, which will be
led by Linda Woodall (as acting Director). Both Directors will sit on the FCA’s Executive Committee.
Risk Outlook
The Business plan includes the FCA’s Risk Outlook setting out the top seven high-level risks the financial
services sector should consider in the coming year. These include:
•
technology developments and their impact on firms’ investment, customers and regulators;
•
how poor culture and controls continue to threaten market integrity;
•
the impact of large back-books on how firms deal with existing customers;
•
consumer outcomes and distribution methods for pensions and retirement income products;
•
poor culture and practice in consumer credit affordability assessments that could result in
unaffordable debt;
04
QUICK LINKS:
Selected Headlines
Asset Management
General
Securities and Markets
Banking and Finance
Financial Crime
FINANCIAL REGULATION
26 March 2015
Insurance
Enforcement
•
the impact of the Consumer Rights Act, including on unfair contract terms; and
•
firms’ systems and controls in relation to financial crime.
Planned initiatives
These include:
Cross sector:
•
a culture review (a new thematic review on whether cultural change programmes in retail and
wholesale banks are driving the right behaviour).
General insurance and protection:
•
technology: use of Big Data and access (a market study to investigate how insurance firms use Big
Data and whether it creates barriers to access to products or services); and
•
a review of the role of appointed representatives.
Pension and Retirement Income:
•
policy, supervision, market studies and thematic work on retirement sales practices; and
•
retirement outcomes - a review into how well the market is working after the introduction of the
reforms and the guidance guarantee, in particular after the full pensions flexibilities are introduced in
April 2015. This review will look at consumer outcomes from advised and non-advised sales.
Retail investments:
•
assessment of firms’ practices on inducements and conflicts of interest; and
•
emerging distribution models (a market study into non-advised sales of investment and protection
products).
Retail lending:
•
mortgages - post-MMR/responsible lending/barriers to lending and market study;
•
work on the collection of unsecured debts; and
•
review of staff remuneration and incentives in consumer credit.
Wholesale banking:
•
the previously announced market study to investigate competition in the investment and corporate
banking sector;
•
work on conflicts of interest in ‘dark pools’.
05
QUICK LINKS:
Selected Headlines
Asset Management
General
Securities and Markets
Banking and Finance
Financial Crime
FINANCIAL REGULATION
26 March 2015
Insurance
Enforcement
Investment management:
•
post-authorisation review of funds (a review of whether UK authorised investment funds and
segregated mandates are operated in line with investors’ expectations as set by marketing material,
disclosure material and investment mandates); and
•
an asset management market study (including the charges paid by investors and the factors that drive
those charges).
The Business Plan 2015/16 is here.
The Business Plan 2015/16 webpage, with Annexes, is here.
The press release is here.
5.2
FCA Consultation Paper CP15/14: Regulated fees and levies: Rates proposals 2015/16 - 26 March 2015 The FCA has published a consultation paper (CP15/14) with the proposed 2015/16 regulatory fees and levies
for the FCA, the Financial Ombudsman Service and the Money Advice Service. The consultation paper also
includes the FCA’s feedback to responses on CP14/26 published in November 2014.
The consultation period ends on 18 May 2015.
CP15/14 is here.
The consultation webpage is here.
The press release is here.
6.
Financial Ombudsman Service
6.1
Plans and budget 2015/2016 - published by FOS - March 2015 - Following consultation in January 2015,
the Financial Ombudsman Service (FOS) has published its plans and budget for 2015/2016.
The FOS ‘Plans for the year ahead’ document is here.
The press release is here.
See also the Insurance section below for an item on FCA CP15/13 which proposes banning opt-out selling across
financial services.
Banking and Finance
7.
Basel Committee on Banking Supervision
7.1
Basel III monitoring - Basel Committee publishes updated FAQs - 24 March 2015 - The Basel Committee
on Banking Supervision has published updated FAQs on Basel III monitoring.
The updated FAQs are here.
06
QUICK LINKS:
Selected Headlines
Asset Management
General
Securities and Markets
Banking and Finance
Financial Crime
FINANCIAL REGULATION
26 March 2015
Insurance
Enforcement
8.
Council of the European Union
8.1
Interchange Fees Regulation - Council publishes text of proposed Regulation - 20 March 2015 - The
Council of the EU has published the text of the Interchange Fees Regulation, in advance of the Council’s
formal adoption of the proposed Regulation.
The text is here.
The procedure file is here.
9.
Official Journal of the European Union
9.1
CRR - Commission Delegated Regulation amending Delegated Regulation on own funds requirements
published in Official Journal - 24 March 2015 - Commission Delegated Regulation (EU) 2015/488 of
4 September 2014 amending Delegated Regulation (EU) 241/2014 as regards own funds requirements for
firms based on fixed overheads under Article 97(4) of the Capital Requirements Regulation (575/2013/EU)
(CRR) has been published in the Official Journal of the European Union it comes into force on 13 April 2015.
The text is here.
10.
European Banking Authority
10.1 CRR and RRD - EBA updates single rulebook Q&As - 20 March 2015 - The EBA has updated its single
rulebook Q&As.
The updated Q&As on the single rulebook are here.
11.
House of Commons Treasury Committee
11.1 Foreign exchange markets and conduct of liquidity auctions - Treasury Committee advocates further
work - 24 March 2015 - The House of Commons Treasury Committee has published a note recommending
that the Treasury Committee, in the next Parliament, should further examine a number of matters arising
from Lord Grabiner’s investigations for the Bank of England. The note includes possible questions for
consideration. The Committee accepts that its successor will need to consider whether further work should
await the conclusion of the Serious Fraud Office’s investigation in relation to liquidity auctions.
The note is here.
The press release is here.
12.
HM Treasury
12.1 Transposition of the Bank Recovery and Resolution Directive - HM Treasury response to consultation
- 26 March 2015 - HM Treasury has published a brief summary of the 14 responses submitted to its July
2014 consultation on transposition of the Bank Recovery and Resolution Directive (2014/59/EU) (RRD). Six
statutory instruments were made following consultation, and they came into force on 1 and 10 January
2015. A revised code of practice on the powers contained in the Banking Act 2009 was published on
12 March 2015. The government states that it is giving further thought to a number of provisions in the RRD
and whether any further provision is needed to give investors and market participants greater clarity on the
policy approach.
07
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Asset Management
General
Securities and Markets
Banking and Finance
Financial Crime
FINANCIAL REGULATION
26 March 2015
Insurance
Enforcement
The consultation response is here.
The consultation webpage is here.
12.2 Restricting tax relief for banks’ compensation expenditure - HM Treasury consultation paper 26 March 2015 - HM Treasury is consulting on restricting tax relief for banks’ compensation expenditure, as
announced in the Budget. The consultation period closes on 29 May 2015.
The consultation paper is here.
The holding page is here.
12.3 Payment system designating orders - made by HM Treasury - 23 March 2015 - Following confirmation
at Budget 2015 that eight payment systems would be designated for regulation by the Payment Systems
Regulator, HM Treasury has made the necessary designation Orders, which all come into force on 1 April
2015.
The orders and press release can be found here.
12.4 Branch closures - Government, consumer groups and banks agree protocol - 26 March 2015 - Consumer
groups, major high street banks and the government have signed an industry-wide agreement to work with
customers and communities to mitigate the effect of branch closures and help to ensure that alternative
banking services are put in place.
The protocol is here.
The press release is here.
13.
Bank of England
13.1 FPC - statement from its meeting and letter from the Governor of the Bank of England to Chancellor
of the Exchequer - 24 March 2015 - The Financial Policy Committee (FPC) has issued a statement from its
meeting of 24 March 2015.
The FPC has also published a formal response from Mark Carney in his role as Chairman of the FPC, to a
letter from George Osborne, Chancellor of the Exchequer on the remit of and recommendations for the FPC.
The statement is here.
The letter is here.
13.2 Real-time gross settlement outage - Bank of England publishes results of independent review and
response - 25 March 2015 - The Bank of England has published an independent report on the real-time
gross settlement (RTGS) outage on 20 October 2014 and its response, which accepts all of the review’s
recommendations and sets out how it intends to implement them. The Bank has already reconstituted its
RTGS Board, and is putting in place an enhanced crisis management framework.
The independent review report is here.
The Bank’s response is here.
08
QUICK LINKS:
Selected Headlines
Asset Management
General
Securities and Markets
Banking and Finance
Financial Crime
FINANCIAL REGULATION
26 March 2015
Insurance
Enforcement
The press release is here.
14.
Financial Conduct Authority
14.1 FCA guidance consultation paper GC15/02: Ex-post risk adjustment to variable remuneration 26 March 2015 - The FCA has published a revised guidance consultation (GC15/2) setting out its expectations
on how firms forming part of a dual-regulated group within the scope of CRD IV (for which SYSC 19D
is proposed to apply) should implement the requirements of the Remuneration Code on ex-post risk
adjustment and sharing good practice observed in the 2014 remuneration round. This guidance is intended
to amend and replace the guidance consulted on in Appendix 6 of CP14/14 (‘Strengthening the alignment of
risk and reward: new remuneration rules’) (July 2014).
The consultation period closes on 7 May 2015.
The guidance consultation paper is here.
The guidance webpage is here.
The July 2014 consultation is here.
14.2 The journey to a sustainable credit market - speech by Christopher Woolard, FCA Director of Strategy
& Competition - 26 March 2015 - Christopher Woolard, FCA Director of Strategy & Competition, has given
a speech on the FCA’s first year as consumer credit regulator, and priorities in the year to come. Mr Woolard
emphasised that consumer credit would remain a priority for the FCA, but that the FCA’s focus would move
from particular ‘products’ to addressing ‘sector wide issues’, and in particular the issue of ‘affordability’.
The speech is here.
15.
New Legislation
15.1 The Financial Services and Markets Act 2000 (Miscellaneous Provisions) Order 2015 (SI 2015/853)
was published on 23 March 2015 and came into force on 24 March 2015. The Order amends the Financial
Services and Markets Act 2000, the Financial Services and Markets Act 2000 (Regulated Activities) Order
2001 (SI 2001/544) and the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005
(SI 2005/1529) in relation to consumer credit.
The Order is here.
The explanatory memorandum is here.
The impact assessment is here.
15.2 The Bank of England Act 1998 (Macro-prudential Measures) Order 2015 (SI 2015/909) was made on
25 March 2015 and comes into force on 6 April 2015. This Order prescribes macro-prudential measures in
relation to the residential housing market.
The Order is here.
The explanatory memorandum is here.
09
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Selected Headlines
Asset Management
General
Securities and Markets
Banking and Finance
Financial Crime
FINANCIAL REGULATION
26 March 2015
Insurance
Enforcement
The impact assessment is here.
15.3 The Bank of England Act 1998 (Macro-prudential Measures)(No.2) Order 2015 (SI 2015/905) was made
on 25 March 2015 and comes into force on 6 April 2015, with the exception of article 4(b), which comes into
force on 1 January 2019.
The Order is here.
The explanatory memorandum is here.
The impact assessment is here.
15.4 The Mortgage Credit Directive Order 2015 (SI 2015/910) was made on 25 March 2015 and will come into
force on various dates between 6 April 2015 and 21 March 2016, in accordance with Article 1 of the Order.
The purpose of the statutory instrument is to implement in part the Mortgage Credit Directive (2014/17/
EU).
On 26 March 2015, the FCA published two authorisation application forms in relation to its powers under
the Order: a ‘Supplement for Second Charge Mortgage Brokers’; and a ‘Supplement for Second Charge
Mortgage Lenders and/or Administrators’.
The Order is here.
The explanatory memorandum is here.
The FCA’s Supplement for Second Charge Mortgage Brokers is here.
The FCA’s Supplement for Second Charge Mortgage Lenders and/or Administrators is here.
16.
Payment Systems Regulator
16.1 PSR policy statement PS15/1: A new regulatory framework for payment systems in the UK - March
2015 - The Payment Systems Regulator (PSR) has published a policy statement setting out the key elements
of the payment systems regulatory regime that is to come into force on 1 April 2015 and reporting on
the key issues arising from Consultation Paper PSR 14/1. It has also published its general directions, and a
policy work programme setting out the priorities for the next year. The PSR has also published draft terms
of reference for two market reviews into (i) the supply of indirect access to payment systems, and (ii) the
ownership and competitiveness of infrastructure provision. Both call for views by 24 April 2015.
The new PSR website is here.
PS15/1 is here.
The following pieces of guidance, contained in the Annexes to PS15/1 can be found here:
•
Powers and Procedures Guidance
•
Objectives Guidance
•
Administrative Priority Framework
10
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Selected Headlines
Asset Management
General
Securities and Markets
Banking and Finance
Financial Crime
•
Penalties Guidance
•
PSR Specific Direction 1 (Access: sponsor banks)
FINANCIAL REGULATION
26 March 2015
Insurance
Enforcement
The PSR webpage on general directions is here.
The general directions are here.
The PSR Annual Plan and Budget is here.
The Indicative Policy Work Programme is here.
The Webpage for the Indicative Policy Work Programme is here.
The Factsheet for the Indicative Policy Work Programme is here.
The press release is here.
PSR market review MS15/1: Market review into the supply of indirect access to payment systems: Draft
Terms of reference is here.
PSR market review MS15/2: Market review into the ownership and competiveness of infrastructure provision
is here.
The holding page is here.
The factsheet is here.
17.
Payments Council
17.1 PSR policy statement - Payment Council publishes response - 25 March 2015 - The Payments Council
has welcomed the PSR policy statement, noting that a crucial consideration will be ensuring that regulation
does not unnecessarily hinder further innovation. The Council states that a new trade association, which will
not have a formal public interest role or quasi-regulatory function, is to replace the Payments Council “this
summer”. The Council intends to publish its first report on the World Class Payments project later this year.
The response is here
Insurance
18.
Official Journal of the European Union
18.1 Solvency II - Commission Implementing Regulation on ITS on procedure for approval of an internal
model published in Official Journal - 20 March 2015 - Commission Implementing Regulation (EU)
2015/460 of 19 March 2015 laying down implementing technical standards (ITS) with regard to the
procedure concerning the approval of an internal model in accordance with the Solvency II Directive
(2009/138/EC) (Solvency II) has been published in the Official Journal of the European Union and came into
force on 21 March 2015.
11
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Asset Management
General
Securities and Markets
Banking and Finance
Financial Crime
FINANCIAL REGULATION
26 March 2015
Insurance
Enforcement
The text is here.
18.2 Solvency II - Commission Implementing Regulation on ITS on the process to reach a joint decision
on the application to use a group internal model published in the Official Journal - 20 March 2015 Commission Implementing Regulation (EU) 2015/461 of 19 March 2015 laying down implementing technical
standards (ITS) with regard to the process to reach a joint decision on the application to use a group internal
model in accordance with the Solvency II Directive (2009/138/EC) (Solvency II) has been published in the
Official Journal of the European Union and came into force on 21 March 2015.
The text is here.
18.3 Solvency II - Commission Implementing Regulation on ITS on the procedures for supervisory approval
to establish special purpose vehicles published in the Official Journal - 20 March 2015 - Commission
Implementing Regulation (EU) 2015/462 of 19 March 2015 laying down implementing technical standards
(ITS) with regard to the procedures for supervisory approval to establish special purpose vehicles (SPVs), for
the cooperation and exchange of information between supervisory authorities regarding SPVs as well as to
set out formats and templates for information to be reported by SPVs in accordance with the Solvency II
Directive (2009/138/EC) (Solvency II) has been published in the Official Journal of the European Union and
came into force on 21 March 2015.
The text is here.
18.4 Solvency II - Commission Implementing Regulation on ITS on supervisory approval procedure to
use undertaking-specific parameters published in the Official Journal - 25 March 2015 - Commission
Implementing Regulation (EU) 2015/498 of 24 March 2015 laying down implementing technical standards
(ITS) with regard to the supervisory approval procedure to use undertaking-specific parameters in
accordance with Solvency II Directive (2009/138/EC) (Solvency II) has been published in the Official Journal
of the European Union and came into force on 26 March 2015.
The text is here.
18.5 Solvency II - Commission Implementing Regulation on ITS on procedures for granting supervisory
approval for the use of ancillary own-fund items published in the Official Journal - 25 March 2015 Commission Implementing Regulation (EU) 2015/499 of 24 March 2015 laying down implementing technical
standards (ITS) with regard to the procedures to be used for granting supervisory approval for the use of
ancillary own-fund items in accordance with the Solvency II Directive (2009/138/EC) (Solvency II) has been
published in the Official Journal of the European Union and came into force on 26 March 2015.
The text is here.
18.6 Solvency II - Commission Implementing Regulation on ITS on procedures for supervisory approval of
the application of a matching adjustment published in the Official Journal - 25 March 2015 - Commission
Implementing Regulation (EU) 2015/500 of 24 March 2015 laying down implementing technical standards
(ITS) with regard to the procedures to be followed for the supervisory approval of the application of a
matching adjustment in accordance with the Solvency II Directive (2009/138/EC) (Solvency II) has been
published in the Official Journal of the European Union and came into force on 26 March 2015.
The text is here.
12
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Selected Headlines
Asset Management
19.
General
Securities and Markets
Banking and Finance
Financial Crime
FINANCIAL REGULATION
26 March 2015
Insurance
Enforcement
European Insurance and Occupational Pensions Authority
19.1 Risk Dashboard - EIOPA publishes Q4 2014 version - 20 March 2015 - The European Insurance and
Occupational Pensions Authority (EIOPA) has published an updated version of its Risk Dashboard for March
2015, incorporating Q4 2014 data.
The updated Risk Dashboard is here.
19.2 Solvency II - EIOPA issues progress report on the follow-up to peer reviews on the pre-application of
internal models - 20 March 2015 - Following two peer reviews on the pre-application of internal models in
mid-2013, and the follow-up conducted in 2014, EIOPA has published a progress report (dated 17 December
2014). In its report, EIOPA notes that the vast majority of its recommendations have already been followedup and the remaining recommendations are planned to be implemented by mid-2015 at the latest.
The progress report is here.
The press release is here.
20.
Prudential Regulation Authority
20.1 PRA Policy Statement PS2/15: Solvency II: a new regime for insurers - March 2015 - The PRA has
published a policy statement (PS2/15) setting out its final rules and supervisory statements implementing
the Solvency II Directive (2009/138/EC) (Solvency II). PS2/15 also contains feedback to five consultation
papers (CP16/14: Transposition of Solvency II: Part 3; CP22/14: The PRA’s approach to with-profits insurance
business; CP23/14 Solvency II approvals; CP24/14: Solvency II: further measures for implementation; and
CP3/15: Solvency II: transitional measures and the treatment of participations).
The PRA has published the following supervisory statements:
•
Insurance general application - SS1/15
•
Own funds - SS2/15
•
The quality of capital instruments - SS3/15
•
The solvency and minimum capital requirements - SS4/15
•
The treatment of pension scheme risk - SS5/15
•
The internal model treatment of participations - SS6/15
•
Supervision of firms in difficulty or run-off - SS7/15
•
Composites - SS8/15
•
Group supervision - SS9/15
•
Third-country branches - SS10/15
•
Regulatory reporting and exemptions - SS11/15
13
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Asset Management
General
Securities and Markets
Banking and Finance
Financial Crime
FINANCIAL REGULATION
26 March 2015
Insurance
Enforcement
•
Lloyd’s - SS12/15
•
Surplus funds - SS13/15
•
With-profits - SS14/15
•
Approvals - SS15/15
•
Conditions governing business - SS16/15
•
Transitional measures on risk-free interest rates and technical provisions - SS17/15.
PS2/15 is here.
The related documents are here.
The holding page, including consultation papers, is here.
The press release is here.
20.2 PRA consultation paper CP11/15: Solvency II - supervisory approval for the volatility adjustment 20 March 2015 - The PRA has published a consultation paper (CP11/15) on the application process for the
‘volatility adjustment’ (VA) under Solvency II. The PRA requests comments on a draft supervisory statement
that sets out its expectations of firms. The draft supervisory statement clarifies what firms should include
in an application to use the VA, how the PRA will use applications to assess satisfaction of the statutory
conditions for approval to use the VA, and how the VA approval process will work. The statement includes
an example of how firms could use their applications to demonstrate compliance with statutory conditions
for approval. Firms may submit applications for approval to apply the VA from 1 April 2015. Further
details on how to submit an application are on the webpage, ‘Approvals and waivers under the Solvency II
Directive’, reported in the item below.
The consultation period closes on 20 April 2015.
The consultation paper is here.
The holding page is here.
The press release is here.
20.3 Solvency II - PRA publishes webpages on approvals and waivers - 20 March 2015 - The PRA has published
a webpage for firms wishing to apply for an approval or waiver under the Solvency II Directive. The webpage
lists transactions that may be approved under Solvency II with information about types of application.
Applications may be made from 1 April 2015. The PRA has also published a further webpage on the process
for Solvency II applications, and has updated its waivers and modifications application webpage to include a
section on Solvency II waivers and access to a standard waiver application form.
The approvals and waivers webpage is here.
More on Solvency II approvals is here.
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More on waivers and modifications is here.
20.4 Solvency II - ABI and PRA launch webcast for NEDs in insurance firms - 25 March 2015 - The Association
of British Insurers and the PRA have published a webcast for non-executive directors of insurance firms,
ahead of Solvency II coming into force on 1st January 2016.
The press release is here.
The webcast is here.
21.
Financial Conduct Authority
21.1 FCA consultation paper CP15/12: Pension wise - recommendation policy - 25 March 2015 - Following the
publication of its standards for Treasury designated guidance providers to meet in delivering Pensions Wise,
the FCA has published a consultation paper (CP15/12) on its policy for making recommendations to the
designated guidance providers and HM Treasury where it finds that providers have breached the standards.
CP15/12 also includes further information on the FCA’s approach to monitoring guidance service providers.
Annex 1 contains the proposed FCA policy for making recommendations on designated guidance providers,
which will be published on the FCA website, but not form part of the FCA Handbook.
The consultation period closes on 8 May 2015.
The FCA intends to publish a policy statement and feedback in summer 2015.
CP15/12 is here.
The Standards for Designated Guidance Providers Instrument 2015 is here.
The holding page is here.
21.2 FCA Final Report MS14/3.3: Retirement income market study - 26 March 2015 - The FCA has published
its final report on its retirement income market study and its proposed remedies. The study looked at
annuities and income drawdown products, and in December 2014, the FCA consulted on its provisional
findings and proposed remedies.
The FCA has confirmed its provisional findings that competition in this market is not working well for
consumers. The remedies are:
•
requiring firms to provide an annuity quotation ranking;
•
redesigning and behaviourally trialling information such as wake-up packs; and
•
in the longer term, working with the government to create a pensions dashboard to allow consumers
to see all their pension pots in one place.
The FCA will be taking these proposals forward.
The final report can be found here.
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The holding page is here.
21.3 FCA consultation paper CP15/13: General Insurance Add-ons Market Study - Proposed Remedies:
Banning opt-out selling across financial services and supporting informed decision-making for add-on
buyers - 25 March 2015 - Following publication of the findings from its General Insurance Add-ons Market
Study (MS14/1) in July 2014, the FCA has now published a consultation paper (CP15/13) on proposals to
ban opt-out selling for all financial services, not just general insurance, and to improve information about
add-ons given to general insurance consumers. The ban would apply to any add-on sales of regulated or
unregulated products offered alongside financial primary products (including legal expenses sold with home
insurance, breakdown or key cover sold alongside motor insurance, or protection cover when taking out a
mortgage or credit card).
The consultation period closes on 25 June 2015, and the FCA intends to publish a policy statement in H2
2015.
The FCA plans to introduce a discussion paper in Q2 2015 considering other options.
CP15/13 is here
The holding page is here
The press release is here.
MS14/1 can be found here.
Asset Management
22.
Council of the European Union
22.1 European Long-Term Investment Funds Regulation - Council publishes text of proposed Regulation 20 March 2015 - The Council of the EU has published the text of the European Long-Term Investment Funds
Regulation in advance of the Council’s formal adoption of the proposed Regulation.
The text is here.
The procedure file is here.
23.
European Commission
23.1 AIFMD - Commission asks Italy and Estonia to enact rules - 26 March 2015 - The European Commission
has formally requested Italy and Estonia to transpose the Alternative Investment Fund Managers Directive
(2011/61/EU) into their national laws and to communicate the transposition measures to the Commission.
If Italy and Estonia do not comply with the formal request within two months, the European Commission
may decide to refer them to the European Court of Justice and propose financial sanctions.
The press release is here.
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24.
General
Securities and Markets
Banking and Finance
Financial Crime
FINANCIAL REGULATION
26 March 2015
Insurance
Enforcement
European Securities and Markets Authority
24.1 Key Investor Information Document for UCITS - ESMA publishes updated Q&As - 26 March 2015 - The
European Securities and Markets Authority (ESMA) has published updated Q&As on the application of the
Key Investor Information Document (KIID) for UCITS.
The Q&As are here.
The press release is here.
24.2 AIFMD - ESMA publishes updated Q&As - 26 March 2015 - ESMA has published updated Q&As on the
application of the AIFMD (2011/61/EU).
The Q&As are here.
The press release is here.
25.
Hedge Fund Standards Board
25.1 Conflicts of interest - HFSB consults - 26 March 2015 - The Hedge Fund Standards Board (HFSB) has
published a consultation paper (CP4/2015) on changes to its Standards to improve the disclosure of conflicts
of interests to investors.
The consultation is open until 12 June 2015.
The consultation paper is here.
The press release is here.
26.
Recent cases
26.1 The Financial Conduct Authority v Capital Alternatives Limited [2015] EWCA Civ 284, 25 March 2015
Collective investment scheme - ‘property’ - pooling - ‘management as a whole’ - s235(3)(a) and (b) FSMA 2000
- construction of penal statutes
The Court of Appeal has rejected an appeal against a decision of the High Court of February 2014 that
four investment schemes (an ‘African Land scheme’ and three Carbon Credit Schemes) were collective
investment schemes within the meaning of section 235 of FSMA 2000, because ‘the property’ was
‘managed as a whole’. The Court did, however, use a different test for deciding whether property is managed
as a whole, rejecting the Judge’s test of whether the elements of individual management were ‘substantial’.
Lord Justice Christopher Clarke said, at paragraph 72:
“It is not necessary that there should be no individual management activity - only that the nature of the
scheme is that, in essence, the property is managed as a whole, to which question the amount of individual
management of the property will plainly be relevant”.
Lord Justice Vos advocated looking at section 235 as a whole, and placed importance on the use of the word
‘arrangements’, which must be with respect to property for the purpose or effect of enabling participants to
receive profits or income from the acquisition, holding, management or disposal of property. He said that
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in considering whether the arrangements had the characteristic of the farm being managed as a whole, one
had to look at the whole gamut of cultivation activities.
Lord Justice Christopher Clarke accepted that just because FSMA contained penal sanctions, it was not
necessary to adopt a restrictive construction, although he did accept that if schemes are to be treated as
collective investment schemes, they must come fairly within the definition contained in section 235.
He also agreed with a number of propositions that the Judge drew from the cases:
“a) that the application of s 235 depends on the specific facts of the case;
b) that, as held by Andrew Smith J in Asset Land the FCA did not have to prove breaches of the FSMA
beyond reasonable doubt although since, as Smith J put it, “the court’s starting point is that the
defendants probably did not behave as the FSA alleges, it has to prove its case the more cogently”;
c) that “arrangements” had a wide meaning and could include non-contractual arrangements which
existed on their own or in parallel with contractual arrangements;
d) that the reference to the “purpose or effect” of the arrangements reflected the fact that what mattered
was the way in which the scheme was run in practice and not contractual terms which might not reflect
reality;
e) that whether there was day-to-day control depended on whether such control was actually exercised
not on whether investors had a contractual right to exercise it; and
f) that whether a scheme was a CIS might change over time, depending on how it was operated in practice”.
The Court also rejected a cross-appeal of the FCA against a decision that there was no pooling of income or
profit merely because deductions from the price of grain for losses were made on a standard basis and not
per property.
The decision is here.
The FCA press release is here
Securities and Markets
27.
International Organization of Securities Commissions
27.1 Code of Conduct Fundamentals for Credit Rating Agencies - IOSCO publishes final form - 24 March
2015 - The International Organization of Securities Commissions (IOSCO) has published its final report
(dated March 2015) on the IOSCO Code of Conduct Fundamentals for Credit Rating Agencies, containing
significant revisions and updates to the current Code.
The final report is here.
The press release is here.
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28.
General
Securities and Markets
Banking and Finance
Financial Crime
FINANCIAL REGULATION
26 March 2015
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Enforcement
European Parliament
28.1 Securities Financing Transactions Regulation - ECON votes in favour - 24 March 2015 - The Economic
and Monetary Affairs committee (ECON) Members of the European Parliament (MEPs) have voted in favour
of the proposed Securities Financing Transactions Regulation. The vote is stated to consolidate the ECON
position. Negotiations with the member states are expected to start in April 2015.
The press release is here.
The procedure file for the Securities Financing Transactions Regulation is here.
29.
European Securities and Markets Authority
29.1 MiFID II - ESMA consults on draft guidelines for complex debt instruments and structured deposits
- 24 March 2015 - ESMA has published a consultation paper on draft Guidelines that clarify the type
of complex debt instruments and structured deposits which can be offered without carrying out an
appropriateness test on the client.
The consultation period closes on 15 June 2015.
ESMA intends to publish final Guidelines in Q4 2015.
The consultation paper is here.
The press release can be found here.
The response document is here.
29.2 CRA Regulation - ESMA issues call for evidence on disclosure requirements for structured finance
instruments - 20 March 2015 - The European Securities and Markets Authority (ESMA) has issued a call
for evidence on the approach to disclosure of private and bilateral transactions for structured finance
instruments. Feedback from the call will serve as input for the ‘phase-in approach’ on the extension of the
disclosure requirements in the Commission Delegated Regulation (EU) 2015/3 of 30 September 2014 with
regard to regulatory technical standards (RTS) on disclosure requirements for structured finance instruments
under the Credit Rating Agency Regulation (1060/2009/EC) (CRA Regulation).
The consultation period closes on 20 May 2015.
ESMA intends to issue a consultation paper during Q4 2015.
The call for evidence is here.
The holding page is here.
The press release is here.
29.3 Guidelines on periodic information to be submitted to ESMA by Credit Rating Agencies - published
by ESMA - 19 March 2015 - ESMA has published Guidelines detailing the information credit rating agencies
should periodically submit to ESMA as part of its ongoing supervision, and for the calculation of supervisory
fees and market share calculations. The Guidelines, contained in Annex 1 of the final report, will come into
force two months after the final translated texts are published on ESMA’s website.
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The report is here.
The press release is here.
29.4 ESMA publishes 2015 Regulatory Work Programme - 23 March 2015 - ESMA has published its revised 2015
Regulatory Work Programme. The Regulatory Work Programme has been revised to take into consideration
budgetary constraints that ESMA will operate under in 2015.
The 2015 Regulatory Work Programme is here.
The press release is here.
30.
House of Lords European Union Committee
30.1 Capital Markets Union - House of Lords European Union Committee publishes report - 17 March
2015 - The House of Lords European Union Committee has published a report (11th of Session 2014-15) in
response to the European Commission’s February Green Paper on the Capital Markets Union. Broadly, the
report supports the European Commission’s proposals, noting that a Capital Markets Union is a timely and
important initiative but warns that it must be rolled out carefully and that it is unlikely to benefit all small
and medium-sized enterprises (SMEs).
The report is here.
The press release is here.
31.
HM Treasury and Financial Conduct Authority
31.1 HM Treasury/FCA consultation paper (CP15/11): Implementation of the Transparency Directive
Amending Directive (2013/50/EU) and other Disclosure Rule and Transparency Rule Changes - 20 March
2015 - HM Treasury and the FCA have published a joint consultation paper (CP15/11) setting out proposals to
implement the Transparency Directive Amending Directive (2013/50/EU), which amends the Transparency
Directive, the Transparency Directive Implementing Directive and the Prospectus Directive; and make
miscellaneous changes to the Disclosure and Transparency Rules (DTRs). The FCA has already implemented
the new requirement to report on payments to governments, and has removed the requirement to publish
interim management statements.
The consultation period closes on 20 May 2015.
The changes are due to be implemented by 26 November 2015.
CP15/11 is here.
The holding page is here.
32.
Financial Conduct Authority
32.1 FCA Discussion Paper DP15/3: Developing our approach to implementing MiFID II conduct of business
and organisational requirements - 26 March 2015 - The FCA has published a Discussion Paper (DP15/3) on
the implementation of MiFID II (2014/65/EU) before it consults on rule changes at the end of the year. Firms,
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trade bodies and consumer groups are invited to submit their views on the approach the FCA should take
towards implementing MiFID II. DP15/3 asks for views on the following topics:
•
the application of MiFID to insurance-based investment products and pensions;
•
the incorporation of MiFID II’s investor protection measures for structured deposits into the FCA
Handbook;
•
whether the FCA should ban third party rebating for discretionary investment management firms;
•
the assessment of local authorities requesting to be treated as professional clients;
•
the appropriate approach to adviser independence, and possible implementation as regards advice on
shares, bonds, derivatives and structured deposits;
•
the possible application of sales-staff remuneration rules to firms not covered by MiFID II;
•
the recording of telephone conversations and electronic communications requirement to firms which
fall within MiFID’s Article 3 exemption (including independent financial advisers and corporate finance
boutiques), and its relationship with the UK’s current domestic regime;
•
costs and charges disclosure; and
•
possible MiFID II inducement rules for advisers, discretionary investment managers and other firms.
It also outlines the FCA’s expectations regarding the application of the appropriateness test to a wider range
of complex products, and on likely restrictions on non-complex products.
Views can be submitted until 26 May 2015.
The European Commission is expected to publish the MiFID II implementing measures later this year, after
which the FCA will consult on rule changes.
The FCA expects to make final rules by July 2016.
MiFID II rules are to take effect on 3 January 2017.
The discussion paper is here.
The press release is here.
The FCA implementation timeline for MiFID II is here.
32.2 FCA Policy Statement PS15/7: Feedback and policy statement on CP14/21 in relation to joint sponsor
proposals - 26 March 2015 - The FCA has published a policy statement (PS15/7) confirming that the FCA
will retain the joint sponsor regime, outlining minor changes to LR 8 relating to joint sponsors reflecting the
feedback received to CP14/02, and publishing the Technical Note consulted on with a minor change as a
result of feedback. The Technical Note and the changes to LR 8 are to take effect from 1 April 2015.
PS15/7 is here.
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The policy statement holding page is here.
33.
Agency for the Cooperation of Energy Regulators
33.1 MiFID II - ACER publishes recommendation to the European Commission - 17 March 2015 - The
Agency for the Cooperation of Energy Regulators (ACER) has published a recommendation addressed to
the European Commission on the regime applying to derivative contracts that have the characteristics
of wholesale energy products that must be physically settled under the MiFID II Directive (2014/65/EU)
(MiFID II).
In its recommendation, ACER refers to technical advice provided by ESMA to the European Commission on
19 December 2014 and states that while it broadly agrees with ESMA’s views, it does have some concerns.
On the basis of these concerns, ACER recommends that the European Commission’s delegated acts should
clarify certain points.
The Recommendation is here.
ESMA’s Technical Advice is here.
See also the Enforcement section below for the latest prison sentence and fine for insider dealing.
Financial Crime
34.
HM Treasury
34.1 Anti-money laundering and counter terrorist finance supervision report 2013-14 - published by HM
Treasury - 24 March 2015 - HM Treasury has published its fourth anti-money laundering and counter
terrorist finance supervision report. The report includes, in chapter 5, good and bad practice by individual UK
supervisors on:
•
how supervisors adopt a risk-based approach;
•
monitoring activity;
•
enforcement action and deterrence;
•
advice and outreach; and
•
information sharing.
The report is here.
The holding page is here.
35.
New Legislation
35.1 The Serious Crime Act 2015 (Commencement No. 1) Regulations 2015 (SI 2015/820) were made on
19 March 2015. Under Regulation 3, section 37 of the Serious Crime Act 2015, relating to the exemption
from civil liability for money-laundering disclosures, will come into force on 1 June 2015.
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The Regulations, and explanatory note, are here
See also the Enforcement section below for the latest prison sentence and fine for insider dealing.
Enforcement
36.
Financial Conduct Authority
36.1 Insider dealing - Former trader sentenced to sentenced to 19 months imprisonment and fined
£100,000 - 19 March 2015 - In November 2014, we reported in this Bulletin that Julian Rifat, a former senior
execution trader at Moore Capital Management LLC, had pleaded guilty to eight instances of insider dealing.
Mr Rifat has now been sentenced at Southwark Crown Court to 19 months imprisonment and been fined
£100,000. He was also ordered to pay £159,402 in costs.
The press release is here.
36.2 Pension advice failings - FCA bans and fines two individuals - 20 March 2015 - The FCA has made
prohibition orders banning Lloyd Pope and Peter Legerton from holding significant influence functions.
The two are former directors of TailorMade Independent Ltd, an advisory firm specialising in pension fund
transfers using self-invested personal pensions (SIPPs). The FCA also fined Pope £93,800 (reduced from
£134,073 for early settlement). But for financial hardship, it would have fined Legerton £120,226 (reduced to
£84,000 for early settlement).
In its final notices, the FCA states that between 22 January 2010 and 20 January 2013, both men breached
Statement of Principle 7 (taking reasonable steps to ensure that the business of the firm for which he
is responsible in his controlled function complies with the relevant requirements and standards of the
regulatory system) by failing to:
•
take reasonable steps to ensure that the firm assessed the suitability of the underlying product within
the SIPP for the customer during the relevant period;
•
identify, disclose, manage and mitigate adequately the conflicts of interest that existed between Mr
Legerton (and other individuals at the firm) and an unregulated introducer during the relevant period;
and
•
take reasonable steps to ensure sufficient oversight of the compliance function within the firm
in order to discharge his CF10 (Compliance oversight) responsibilities between 4 August 2011 to
20 January 2013.
The final notice for Lloyd Pope is here.
The final notice for Peter Legerton is here.
The press release is here.
See the Banking section above for an item on an HM Treasury consultation paper on restricting tax relief for banks’
compensation expenditure.
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This Bulletin is prepared by the Financial Regulation Group of Slaughter and May in London. The Group comprises
a team of lawyers with expertise and experience across all sectors in which financial institutions operate.
We advise on regulatory issues affecting firms across the financial services sector, including banks, investment firms,
insurers and reinsurers, brokers, asset managers and funds, non-bank lenders, payment service providers, e-money
issuers, exchanges and clearing systems. In addition, our leading financial regulatory investigations practice is
regularly instructed by financial institutions requiring specialist knowledge of financial services regulation together
with experience in high profile and complex investigations and contentious regulatory matters.
Most of the projects that we advise on have an extensive international or cross-border element. We work in
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Our Financial Regulation Group also produces occasional briefing papers and other client publications. The five
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The Group’s recent work includes advising:
•
a number of banking groups in relation to the new banking structural reforms, including the new ring-fencing
regime;
•
•
•
•
Standard Life plc on its acquisition of Ignis Asset Management Limited from Phoenix Group Holdings plc;
•
Deutsche Bank in relation to several simultaneous investigations in multiple jurisdictions relating to LIBOR
and a global financial services institution in relation to a number of regulatory investigations into foreign
exchange trading at several banks;
•
Banco Santander on a pan-European and global asset management joint venture with leading global private
equity firms Warburg Pincus and General Atlantic;
•
a number of multi-national clients in relation to the UK, EU, and US economic and trade sanctions regimes.
the UK Government on the establishment of the British Business Bank;
Pollen Street Capital Limited’s sale of Moneycorp to international private equity group, Bridgepoint;
international and specialist insurer and reinsurer, Catlin Group Limited, on the acquisition of it by global
insurer and reinsurer, XL Group plc;
If you would like to find out more about our Financial Regulation Group or require advice on a financial regulation
matter, please contact one of the following or your usual Slaughter and May contact:
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Ben Kingsley Michael Sholem
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