The month ahead in financial services regulatory developments…

30 August 2019

In this blog post, we round-up forthcoming developments in the UK and at EU and International levels in financial services regulation which are expected for September 2019.

1 Sep	FCA restrictions on sale of CFD-like options to retail customers come into force The European Market Infrastructure Regulation (EMIR) initial margin requirement commencement date for counterparties with portfolios in excess of €750 billion
3 Sep	Application date of Commission Delegated Regulation on minimum actions to mitigate money laundering and terrorist financing risk for branches/subsidiaries in certain third countries, under MLD IV
4 Sep	Internal model firms to provide data on non-modellable risk factors to the European Banking Authority (EBA)
4-5 Sep	Joint FSI-IADI Conference on Financial Stability and Deposit Insurance, Basel
6 Sep	Deadline for responses to Fixed Income, Currencies and Commodities (FICC) Markets Standards Board draft statement of good practice on conflicts of interest
9 Sep	SMCR: Form K (conversion notification for core and enhanced firms only) available; and Form A (applying for a senior manager to be approved) available.
11 Sep	Deadline for responses to EU Commission consultation on Connecting Europe Facility Digital Programme 2021-2027
12 Sep	FCA buy now pay later (BNPL) disclosure rules apply
12-13 Sep	OECD Blockchain Policy Forum
13 Sep	Changes to PRA supervisory statements (SS17/13 and SS31/15) relating to credit risk mitigation (eligibility of guarantees as unfunded credit protection) apply Deadline for responses to FCA consultation (CP19/20) on approach to assessment of adequate financial resources Deadline for feedback on the PRA Annual Report Deadline for responses to EU Commission consultation on development of an EU-wide taxonomy for environmentally-sustainable economic activities
14 Sep	EBA revised payment services directive (PSD2) guidelines apply: exemption from the fallback mechanism under the regulatory technical standards (RTS) on strong customer authentication (SCA) and common and secure open standards of communications (CSC) fraud reporting relating to SCA exemptions See FCA PSD2 webpage for UK implementation information
15 Sep	Deadline for responses to FCA CP19/23 on signposting to travel insurance for consumers with medical conditions Certain significant institutions to submit questionnaire on significance of benchmark reforms and transition to the European Central Bank (ECB)
26 Sep	FCA Board meeting
27 Sep	Deadline for responses to PRA CP14/19 Pillar 2 liquidity: PRA110 reporting frequency threshold when a firm is in stress Deadline for responses to Bank of England (BoE) discussion paper (DP) on its approach to risk management of collateral referencing LIBOR for use in the Sterling Monetary Framework
30 Sep	FCA asset management market study (AMMS) rules take effect requiring authorised fund managers to: appoint a minimum of two independent directors to their boards; and conduct an annual assessment of value, using a number of specific criteria, and to report publicly on the outcome. Deadline for responses to FCA call for input on a cross-sector sandbox First deadline for insurers to submit information to PRA in relation to the Insurance Stress Test 2019 Deadline for responses to EBA consultation on loan origination and monitoring guidelines, including creditworthiness assessments EBA outsourcing guidelines enter into force; recommendation on cloud outsourcing repealed Deadline for responses to European Insurance and Occupational Pensions Authority (EIOPA) consultation on proposed guidelines on outsourcing to cloud service providers
Sep	Policy statement (PS) to FCA CP19/18 on publication of overdraft fees and charges expected Banks and insurers able to start submitting data on Directory individuals using the FCA Connect system BoE launches delayed biennial exploratory scenario (an element of stress testing) HM Treasury (HMT) to send Treasury Committee a report on HMRC's role as an anti-money laundering (AML) supervisor and its relationship with the office for professional body AML supervision (OPBAS) UK Finance target date for voluntary alternative dispute resolution (ADR) arrangement for larger small and medium sized enterprises (SMEs)
Autumn	Feedback expected on FCA guidance consultation (GC19/2) on the FCA's expectations of insurance product manufacturers and distributors FCA research and stakeholder engagement on the review of retail distribution review (RDR) and financial advice market review (FAMR) PS to FCA CP19/21 on Proxy Advisors (Shareholders’ Rights) Regulation implementation (Decision Making and Penalties Manual (DEPP) and the Enforcement Guide (EG)) expected FCA update on potential duty of care work expected BoE DP expected on scenario design for climate stress test for UK financial institutions BoE and PRA to commence design work on stress testing the UK financial system for resilience against different climate pathways PRA to issue an SS on cloud outsourcing Financial Ombudsman Service (FOS) strategic proposal on future operations expected

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Bank Accounts and Payment Services Complaints Conflicts of Interest Corporate Crime Credit and Loans Enforcement FinTech Investigations Investment Management Money Laundering Outsourcing Prudential Retail Investments and Pensions UK

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The month ahead in financial services regulatory developments…

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