Navigating Regulatory Compliance: Investment Management Monthly



It is our pleasure to welcome you to our first Monthly Regulatory Update for investment managers. We understand that compliance and business teams have day jobs and therefore this regulatory update provides commentary on those items which we think are important. We have set out this update in the form of a report which can be distributed to your colleagues.

In this update, we review February’s highlights, including the delay to MiFID II, the Benchmark Regulation, the FCA’s review of firms’ liquidity management, the FCA and PRA’s decision not to apply the bonus cap to small CRD firms and ESMA’s first Supervisory Work Programme.

What were February’s highlights for investment managers?

MiFID II delay

The biggest news this month is that the European Commission and European Parliament proposed to delay the MiFID II and MiFIR effective and transposition dates each by one year respectively.

Benchmark Regulation

This is a very broadly written piece of regulation which has the potential to bring a wider variety of benchmark usage into the scope of regulation for the first time. Careful consideration needs to be given to its scope and ESMA this month issued a discussion paper which, in part, seeks to provide clarity on this area.

Liquidity management

The FCA reviewed a number of firms’ practices in relation to managing liquidity around redemptions in fixed income funds. The FCA wants to ensure that there is fair treatment of both redeeming and remaining investors. 

Bonus cap

It is good news that the FCA and PRA have decided not to apply the EBA guidelines on bonus caps to small CRD firms and this signals that the regulators don’t have the appetite to apply European guidelines where they think the European authorities have overstepped the mark. 

ESMA’s first Supervisory Work Programme

We thought it was interesting that ESMA is going to conduct “a thematic study on the operation of home and host responsibilities under AIFMD and UCITS with a view to clarifying the respective responsibilities of the NCAs and promoting the smooth operation of the EU passports for marketing and management.”

Download the full Investment Management Monthly Regulatory Update


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