FCA Director of Market Oversight Comments on FCA's Expectation of Compliance with MAR Surveillance Technology Requirement

Julia Hoggett, the Financial Conduct Authority's ("FCA") Director of Market Oversight, delivered a speech on 14 November 2017 at the Recent Developments in the Market Abuse Regime conference in London, in which she made remarks regarding the FCA's expectation that firms be in compliance with all requirements under the Market Abuse Regime ("MAR"), including the surveillance technology requirement.

Less than 100 days until MiFID II – Are you ready?

The MiFID II deadline is fast approaching and many firms are in the midst of implementing the proper operational and regulatory changes necessary to comply with the new European directive. How do you know your implementation is in-line with your peers and you have the balance right between commercial expectations and compliance with the directive? Have you independently tested what you’ve done to ensure you’ve covered every last detail?

UK FCA Takes a Hard Line on MiFID II’s Rules on Paying for Research to Non-EU Delegates

Last week, the Alternative Investment Management Association (“AIMA”) released the text of a letter it received from Stephen Hanks, Head of Market Policy at the FCA. The letter was dated July 19, 2017, but sent a week ago. The letter is a response to one sent by AIMA back in April, asking the FCA to clarify their position on how MiFID II requirements should be extended to non-European Union ("EU") delegates (e.g., those acting as sub-advisers), including its new rules on paying for research. 

The FCA’s 2nd Policy Statement on Implementing MiFID II: What do I need to know?

On 3 July 2017, just hours before MiFID II’s transposition deadline passed, the FCA published its Markets in Financial Instruments Directive II Implementation – Policy Statement II (PS17/14). In this document, the FCA sets out its final position on the conduct of business rules, many of which will significantly impact the way your firm carries out its commercial activities.

FCA Identifies Cybersecurity as Top Risk in 2017/18 Business Plan

The FCA identified cybsersecurity as a top priority in their recently published 2017/18 Business Plan. In the plan, FCA Chairman John Griffith-Jones said, "Of the increasing risk areas that we have identified, one in particular stands out – cyber resilience. Cyber-attacks are increasing in number, scale and sophistication."

UK FCA Annex IV Reporting Amendments for non-EU managers to take effect on June 29, 2017

On January 25, 2017 the UK Financial Conduct Authority (FCA) released an amendment to the Financial Services and Markets Act 2000 which confirms the FCA’s plans to increase the scope of Annex IV reporting rules under the EU Alternative Investment Fund Managers Directive (AIFMD).

Governance Best Practices and Preparing for the FCA's Senior Managers & Certification Regime

As asset management firms’ businesses grow in size and complexity, how do they continue to meet the FCA’s expectations around governance? What constitutes good governance in the FCA’s view? What actions has the FCA taken recently in relation to senior management arrangements, systems and controls? And how are firms preparing for (or have prepared for) the implementation of the Senior Managers & Certification Regime (SM&CR)?

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FCA releases finalized guidance on outsourcing to the cloud and other third party IT services

The FCA has finalized guidance to clarify requirements on firms when outsourcing to the cloud and other third party IT providers, the aim is for firms to identify and manage operational risks associated with use of third parties. This newly issued guidance is in addition to general outsourcing requirements already detailed in SYSC 8 within the FCA Handbook.

We recommend that firms read the guidance paper in detail, key points include the following: